This is the accessible text file for GAO report number GAO-12-64 
entitled 'Compacts 0f Free Association: Improvements Needed to Assess 
and Address Growing Migration' which was released on November 14, 2011. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

November 2011: 

Compacts of Free Association: 

Improvements Needed to Assess and Address Growing Migration: 

GAO-12-64: 

GAO Highlights: 

Highlights of GAO-12-64, a report to congressional requesters. 

Why GAO Did This Study: 

U.S. compacts with the freely associated states (FAS)-—the Federated 
States of Micronesia (FSM), the Marshall Islands, and Palau—-permit 
FAS citizens to migrate to the United States and its territories (U.S. 
areas) without regard to visa and labor certification requirements. 
Thousands of FAS citizens have migrated to U.S. areas (compact 
migrants)—particularly to the Commonwealth of the Northern Mariana 
Islands (CNMI), Guam, and Hawaii, which are defined as affected 
jurisdictions. In fiscal year 2004, Congress appropriated $30 million 
annually for 20 years to help defray affected jurisdictions’ costs for 
migrant services (compact impact). Though not required, affected 
jurisdictions can report these costs to the Department of the Interior 
(Interior), which allocates the $30 million as impact grants in 
proportion to compact migrant enumerations required every 5 years. 

This report (1) describes compact migration, (2) reviews enumeration 
approaches, (3) evaluates impact reporting, and (4) reviews Interior 
grants related to compact impact. GAO reviewed U.S. agency data, 
recent enumerations, impact reports, and grants and it also 
interviewed officials, employers, and migrants in the affected 
jurisdictions. 

What GAO Found: 

Combined data from the U.S. Census Bureau’s (Census) 2005-2009 
American Community Survey (ACS) and the required enumeration in 2008 
estimate that a total of roughly 56,000 compact migrants from the FSM, 
the Marshall Islands, and Palau-—nearly a quarter of all FAS citizens—-
were living in U.S. areas. Compact migrants resided throughout U.S. 
areas, with approximately 58 percent of all compact migrants living in 
the affected jurisdictions. According to the 2008 required 
enumeration, compact migrant populations continued to grow in Guam and 
Hawaii and were roughly 12 percent of the population of Guam and 1 
percent of the population of Hawaii. 

Working under agreements with Interior, Census used a different 
approach for the most recent enumeration than for prior enumerations, 
employing two methods in 2008: (1) a one-time survey in Guam and the 
CNMI and (2) a tabulation of existing multiyear ACS data for Hawaii. 
The affected jurisdictions opposed the change in approach. The 2008 
approach allowed for determining the precision of the estimates but 
did not yield comparable results across jurisdictions or detailed 
information on compact migrants. Interior and Census officials have a 
preliminary plan for the required 2013 enumeration but Interior has 
not determined its cost or assessed its strengths and limitations. 

The methods used by affected jurisdictions to collect and report on 
compact impact have weaknesses that reduce their accuracy. For fiscal 
years 2004 through 2010, Hawaii, Guam and the CNMI reported more than 
$1 billion in costs associated with providing education, health, and 
social services to compact migrants. However, some jurisdictions did 
not accurately define compact migrants, account for federal funding 
that supplemented local expenditures, or include revenue received from 
compact migrants. Although Interior is required to report to Congress 
any compact impacts that the affected jurisdictions report to 
Interior, it has not provided the affected jurisdictions with adequate 
guidance on estimating compact impact. Compact migrants participate in 
local economies through employment, taxation and consumption, but data 
on these effects are limited. 

From fiscal years 2004 to 2010, Interior awarded approximately $210 
million in compact impact grants to the affected jurisdictions, which 
used the funds primarily for budget support, projects, and purchases 
in the areas of education, health, and public safety. In Guam and 
Hawaii, government officials, service providers, and compact migrants 
discussed approaches to more directly address challenges related to 
migration by bridging language barriers, providing job training, and 
increasing access to services. The amended compacts also made 
available $808 million in sector grants for the FSM and the Marshall 
Islands from fiscal years 2004 to 2010. Sector grants are jointly 
allocated by the joint U.S.-FSM and U.S.-Marshall Islands management 
committees and have been used primarily in the FAS for health and 
education. Few sector grants directly address issues that concern 
compact migrants or the affected jurisdictions. The committees had not 
formally placed compact impact on their annual meeting agendas until 
2011 and have not yet allocated any 2012 sector grant funds to 
directly address compact impact. 

What GAO Recommends: 

GAO recommends that Interior assess the 2013 enumeration approach, 
disseminate adequate guidance on estimating compact impact, and 
encourage uses of grants that better address compact migrants’ impact 
and needs. Interior generally agreed with the report but did not 
support the recommendation on grant uses. 

View [hyperlink, http://www.gao.gov/products/GAO-12-64] or key 
components. For more information, contact David B. Gootnick at (202) 
512-3149 or gootnickd@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

U.S. Census Data Show Compact Migrants throughout U.S. Areas, with 
Growing Populations in Guam and Hawaii: 

Enumeration Approach in 2008 and Preliminary Approach for 2013 Have 
Strengths and Limitations: 

Estimates of Rising Compact Impact Costs Have Weaknesses, and Guidance 
on Impact Reporting Is Lacking: 

Interior Grants Only Partially Address Compact Impact: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Growth and Impact of Marshallese Compact Migration in 
Arkansas: 

Appendix III: American Community Survey Estimates of Compact Migrants: 

Appendix IV: 2010 Decennial Census Data on Micronesians by Race: 

Appendix V: Attributes of 2003 and 2008 Approaches to Enumerating 
Compact Migrants: 

Appendix VI: Compact Impacts Reported by Affected Jurisdictions: 

Appendix VII: Interior-Awarded Compact Impact Grants to Affected 
Jurisdictions from 2004 to 2011: 

Appendix VIII: Comments from the Department of the Interior: 

Appendix IX: Comments from the Census Bureau: 

Appendix X: Comments from the Government of Hawaii: 

Appendix XI: Comments from the Government of Guam: 

Appendix XII: Comments from the Government of the Commonwealth of the 
Northern Mariana Islands: 

Appendix XIII: Comments from the Government of Arkansas: 

Appendix XIV: Comments from the Government of the Federated States of 
Micronesia: 

Appendix XV: Comments from the Government of the Republic of the 
Marshall Islands: 

Appendix XVI: Comments from the Government of the Republic of Palau: 

Appendix XVII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Affected Jurisdictions' Reported Compact Impact, by Sector, 
2004-2010: 

Table 2: Eligibility Status of Compact Migrants for Selected Federal 
Benefit Programs: 

Table 3: Sector Grant Awards in the FSM and the Marshall Islands, 
Fiscal Year 2011: 

Table 4: Estimated Costs for Services to Arkansas Compact Migrants, 
2004-2010: 

Table 5: Compact Migrant Populations by U.S. Area of Residence and FAS 
of Origin: 

Table 6: 2010 Census Counts of Marshallese by State: 

Table 7: Attributes of 2003 and 2008 Census Approaches to Compact 
Migrant Enumerations: 

Table 8: Affected Jurisdiction Compact Impact Estimates, 1986-2010: 

Table 9: Compact Impact Grant Awards to Affected Jurisdictions, 2004- 
2011: 

Figures: 

Figure 1: Locations of Freely Associated States and Affected 
Jurisdictions: 

Figure 2: Estimated Numbers of Compact Migrants in U.S. Areas, 2005- 
2009: 

Figure 3: Estimated Compact Migrant Population in Guam, Hawaii, and 
the CNMI, 1993-2008: 

Figure 4: Estimated Percentages of Total Populations of Guam, Hawaii, 
and the CNMI Who Are Compact Migrants, 1993-2008: 

Figure 5: Reported Compact Impact Costs, 1996-2010: 

Figure 6: Comparison of Compact Impact Costs Reported by Affected 
Jurisdictions and Compact Impact Grants Awarded by Interior, 2004-2010: 

Figure 7: Northwest Arkansas: 

Abbreviations: 

ACS: American Community Survey: 

CHIP: Children's Health Insurance Program: 

CHIPRA: Children's Health Insurance Program Reauthorization Act of 
2009: 

CNMI: Commonwealth of the Northern Mariana Islands: 

COFA: Compact of Free Association: 

FAS: freely associated state: 

FSM: Federated States of Micronesia: 

GMHA: Guam Memorial Hospital Authority: 

INA: Immigration and Nationality Act: 

OIA: Office of Insular Affairs: 

OMB: Office of Management and Budget: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

November 14, 2011: 

Congressional Requesters: 

The Federated States of Micronesia (FSM),[Footnote 1] the Republic of 
the Marshall Islands, and the Republic of Palau have entered into 
compacts of free association with the United States. The compacts 
provide, among other things, for citizens of these three freely 
associated states (FAS) to enter and reside indefinitely in the United 
States, including its territories, without regard to the Immigration 
and Nationality Act's (INA) visa and labor certification requirements. 
Since the compacts went into effect--in 1986 for the FSM and the 
Marshall Islands and 1994 for Palau--thousands of migrants from these 
countries have established residence in U.S. areas, particularly in 
Guam, Hawaii, and the Commonwealth of the Northern Mariana Islands 
(CNMI).[Footnote 2] 

In 2003, Congress approved amended compacts with the FSM and the 
Marshall Islands.[Footnote 3] In the amended compacts' enabling 
legislation, Congress extended additional economic assistance to the 
two countries and authorized and appropriated $30 million annually for 
20 years for grants to Guam, Hawaii, the CNMI, and American Samoa, 
which it deemed "affected jurisdictions," to help defray the cost of 
services to compact migrants.[Footnote 4] Congress directed the 
Department of the Interior (Interior) to divide these compact impact 
grants among the affected jurisdictions in proportion to the most 
recent enumeration of those compact migrants residing in each 
jurisdiction. 

In 2003 and 2008, the U.S. Census Bureau (Census), working under an 
agreement with Interior, performed the required enumerations, and 
Interior plans another enumeration in 2013. However, affected 
jurisdictions have expressed continuing concerns that they do not 
receive adequate compensation for the growing cost of providing 
government services to compact migrants.[Footnote 5] In addition, 
thousands of compact migrants have moved to other states that are not 
eligible to receive compact impact grants. Among these states, 
Arkansas has attracted many Marshallese who have moved there for 
employment in the poultry industry. 

At your request, this report (1) describes compact migration to the 
United States; (2) reviews approaches to the required enumerations of 
compact migrants; (3) evaluates impact reporting from the affected 
jurisdictions; and (4) reviews Interior grants related to compact 
migration. Also at your request, appendix II provides information on 
the growing Marshallese migrant population of northwest Arkansas and 
their impact. 

To prepare this report, we reviewed previous reports on compact 
migration and cost estimation, Interior's existing compact migrant 
enumerations and impact reports, as well as the supporting 
documentation and methodologies used to prepare the enumerations and 
impact reports. We also interviewed officials at Interior, Census, and 
the Department of State, as well as local and FAS government officials 
and migrants in Guam, Hawaii, the CNMI, and Arkansas. 

To approximate the dispersion of compact migrants, we purchased from 
Census a special tabulation of their American Community Survey (ACS) 
data gathered from 2005 to 2009. We assessed Interior and Census 
approaches to required enumerations against the requirements of the 
amended compacts' enabling legislation and Office of Management and 
Budget (OMB) guidelines.[Footnote 6] To assess compact impact cost 
reporting, we reviewed affected jurisdictions' impact reports since 
2004 and compared these reports to cost estimation criteria.[Footnote 
7] To assess Interior's guidance on compact impact reporting and its 
congressional reporting, we reviewed the requirements in the amended 
compacts' enabling legislation and Interior's existing guidelines, and 
assessed the existing Interior congressional report. To describe 
compact migrants' role in the economy, we used data from earlier FAS 
migrant surveys supplemented where possible with additional 
information from local agencies and other literature. To assess 
Interior's compact impact grants, we reviewed the requirements of the 
amended compacts' enabling legislation, Interior's Financial 
Assistance Manual, and all Interior compact impact grant files. To 
identify relevant Interior grants to the freely associated states, we 
collected grant allocation data and discussed the grants with Interior 
officials. For complete details on our scope and methodology, see 
appendix I. 

We conducted this performance audit from September 2010 through 
October 2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives: 

Background: 

The FSM, the Marshall Islands, and Palau are among the smallest 
countries in the world. In 2008, the three FAS had a combined resident 
population of approximately 179,00[Footnote 8]0--104,000 in the FSM, 
54,000 in the Marshall Islands, and 21,000 in Palau.[Footnote 9] 

Establishment of Compacts of Free Association: 

In 1947, the United States entered into a trusteeship with the United 
Nations and became the administering authority of the FSM,[Footnote 
10] the Marshall Islands, and Palau.[Footnote 11] The four states of 
the FSM voted in 1978 to become an independent nation, and the 
Marshall Islands established a constitutional government and declared 
itself a republic in 1979. Both the FSM and the Marshall Islands 
remained subject to the authority of the United States under the 
trusteeship agreement until 1986, when a Compact of Free Association 
went into effect between the United States and the two nations. 
[Footnote 12] In 1994, Palau also entered a Compact of Free 
Association with the United States and became a sovereign state. 
[Footnote 13] 

Under the compacts, FAS citizens are exempt from meeting the visa and 
labor certification requirements of the Immigration and Nationality 
Act (INA) as amended. The migration provisions of the compacts allow 
compact migrants to enter the United States (including all U.S. 
states, territories, and possessions) and to lawfully work and 
establish residence indefinitely. 

In addition, under the compacts, the United States provided economic 
assistance, and access to certain federal services and programs, among 
other things. Also under the compacts, the United States has a 
responsibility for the defense of the FAS, and the compacts provide 
the United States with exclusive military use rights in these 
countries. A further compact-related agreement with the Marshall 
Islands secured the United States access to the U.S. military 
facilities on Kwajalein Atoll, which are used for missile testing and 
space tracking activities. 

In the 1986 compacts' enabling legislation, Congress stated that it 
was not its intent to cause any adverse consequences for United States 
territories and commonwealths and the state of Hawaii. Congress 
further declared that it would act sympathetically and expeditiously 
to redress any adverse consequences and authorized compensation for 
these areas that might experience increased demands on their 
educational and social services by compact migrants from the Marshall 
Islands and the FSM. The legislation also required the President to 
report and make recommendations annually to the Congress regarding 
adverse consequences resulting from the compact and provide statistics 
on compact migration. In November 2000, Congress made the submission 
of annual impact reports optional and shifted the responsibility for 
preparing compact impact reports from the President, with Interior as 
the responsible agency, to the governors of Hawaii and the 
territories.[Footnote 14] 

Amended Compacts, 2003: 

In December 2003, Congress approved the amended compacts with the FSM 
and the Marshall Islands and took steps in the amended compacts' 
enabling legislation to address compact migrant impact in U.S. areas. 
The legislation restated Congress's intent not to cause any adverse 
consequences for the areas defined as affected jurisdictions--Guam, 
Hawaii, the CNMI, and American Samoa.[Footnote 15] 

Compact Impact Grants To Affected Jurisdictions: 

The act authorized and appropriated $30 million[Footnote 16] for each 
fiscal year from 2004 to 2023 for grants to the affected 
jurisdictions, to aid in defraying costs incurred by these 
jurisdictions as a result of increased demand for health, educational, 
social, or public safety services, or for infrastructure related to 
such services, due to the residence of compact migrants in their 
jurisdiction.[Footnote 17] Interior's Office of Insular Affairs (OIA) 
reviews the affected jurisdictions' annual proposals for the use of 
the funds and provides them to affected jurisdictions as grants. 
Grants are to be used only for health, educational, social, or public 
safety services, or infrastructure related to such services due to the 
residence of compact migrants.[Footnote 18] 

Required Enumerations Of Compact Migrants: 

Under the amended compacts' enabling legislation, the affected 
jurisdictions are to receive their portion of the $30 million per year 
through 2023 in proportion to the number of compact migrants living 
there, as determined by an enumeration to be undertaken by Interior 
and supervised by Census or another organization at least every 5 
years beginning in fiscal year 2003. The act permits Interior to use 
up to $300,000 of the compact impact funds, adjusted for inflation, 
for each enumeration. 

The legislation defines the population to be enumerated as persons, or 
those persons' children under the age of 18, who pursuant to the 
compacts are admitted to, or resident in, an affected jurisdiction as 
of the date of the most recently published enumeration.[Footnote 19] 

Compact Impact Reports: 

In contrast to the original compacts' enabling legislation, the 
amended compacts' enabling legislation permits, but does not require, 
affected jurisdictions to report on compact migrant impact. If 
Interior receives such reports from the affected jurisdictions, it 
must submit reports to Congress that include, among other things, the 
Governor's comments and Administration's analysis of any such impacts. 

Sector Grants To The FSM And The Marshall Islands: 

Under the initial compacts with the FSM and the Marshall Islands, the 
United States provided $2.1 billion in economic assistance to these 
governments. Under the amended compacts, the United States will 
provide an estimated combined total of $3.6 billion in economic 
assistance, much of it in a form known as "sector grants," in annually 
decreasing amounts from 2004 through 2023.[Footnote 20] The amended 
compacts require that the sector grants be targeted to sectors such as 
education, health care, the environment, public sector capacity 
building, private sector development, and public infrastructure, or 
for other sectors as mutually agreed, with priority given to education 
and health. 

The amended compacts also established two management committees, the 
U.S.-Federated States of Micronesia Joint Economic Management 
Committee and the U.S.-Republic of the Marshall Islands Joint Economic 
Management and Financial Accountability Committee. Each committee has 
two FAS representatives and three U.S. representatives from, 
respectively, Interior, the Department of State, and the Department of 
Health and Human Services, with the Interior representative serving as 
chair. These committees review and approve compact grant allocations 
and performance objectives for the upcoming year on an annual basis 
and may attach conditions to the grants.[Footnote 21] 

Figure 1 shows the locations of the FAS and the affected jurisdictions. 

Figure 1: Locations of Freely Associated States and Affected 
Jurisdictions: 

[Refer to PDF for image: map] 

Depicted on the map: 

Freely Associated States: 
Federated States of Micronesia; 
Republic of the Marshall Islands. 

Affected jurisdictions: 
American Samoa; 
Commonwealth of the Northern Mariana Islands; 
Hawaii. 

Source: Map Resources. 

Note: Circles around each location illustrate the general vicinity of 
each island area. They do not correspond to territorial boundaries or 
exclusive economic zones. 

[End of figure] 

Sources of Compact Migrant Population Data: 

Census has gathered data through multiple efforts that can be used to 
describe aspects of the FAS migration to U.S. areas. Data are 
currently available through Census's decennial censuses, which cover 
all U.S. areas, and its American Community Survey (ACS), which covers 
the 50 states, the District of Columbia and Puerto Rico. In addition, 
under agreements with Interior, Census has conducted special 
enumerations of compact migrants in affected jurisdictions, such as in 
2003 and the 2008 enumeration required by the amended compacts' 
enabling legislation. The next such required enumeration must occur by 
2013. 

Decennial Census: 

The decennial census is an enumeration of the U.S. population that is 
constitutionally required every 10 years. The 2010 decennial census 
data was gathered as of a specific day: April 1, 2010. 

* The 2010 decennial census in the 50 states is a 10-question survey 
that gathers limited demographic[Footnote 22] data such as sex, age, 
and race. The 2010 decennial census race question provided multiple 
choices for respondents to identify the race of each member of the 
household, with one choice being "Other Pacific Islander." Respondents 
could identify multiple races for each individual and could further 
identify themselves by writing in a specific race. The decennial 
census in the 50 states does not collect respondents' place of birth 
or year of entry, both of which are needed to identify those who 
arrived during the period of the compacts and are defined as compact 
migrants by the amended compacts' enabling legislation. 

* Unlike the census in the 50 states, the decennial census in the 
insular areas--including Guam and the CNMI--is a detailed survey that 
collects a variety of demographic and economic information including 
respondents' place of birth and year of entry, both of which are 
needed to identify compact migrants. 

American Community Survey: 

Begun in 2005, the ACS uses a series of monthly samples to produce 
data for the same small areas of the United States (census tracts and 
block groups) used in the decennial census and formerly surveyed via 
the decennial census long form. To conduct the ACS, Census mails 
survey forms to selected households and, if a household does not 
respond, follows up by telephone and sometimes in person. Census then 
uses the information obtained from the surveys to estimate results for 
the entire population of larger areas that have a determined level of 
statistical precision. The ACS collects a variety of demographic and 
economic information on an ongoing basis, including data such as place 
of birth and year of entry that can be used to identify compact 
migrants. 

The ACS reports estimates from individual or multiple years of data 
rather than point-in-time counts, such as the decennial census 
provides. 

Enumerations Of Compact Migrants: 

Interior has conducted four sets of enumerations of compact migrants 
in affected jurisdictions. The 1993, 1998, and 2003 surveys used the 
"snowball" technique; Census, working under an interagency agreement 
with Interior, employed a two-pronged approach in 2008.[Footnote 23] 

² In the snowball technique used by Census for the 2003 survey and by 
prior surveys, trained workers who spoke the FAS languages asked the 
respondent in compact migrant households for referrals to other 
compact migrant households until they had surveyed every identified 
compact migrant. The surveys provided a count of compact migrants and 
demographic information such as employment, occupation, education, and 
reasons for migration. The snowball technique is a nonprobability 
method.[Footnote 24] 

² The two-pronged approach used one approach in Guam and the CNMI and 
another in Hawaii. In Guam and the CNMI, Census designed a block 
sample probability survey[Footnote 25]and collected only the data 
needed to establish whether the respondents and their children could 
be classified as compact migrants. Census used the survey results to 
produce an estimate for each affected jurisdiction's 
population.[Footnote 26] In Hawaii, Census tabulated only the data 
from the 2005, 2006, and 2007 ACS needed to identify migrants and 
their children. 

Interior has used the two most recent enumerations--in 2003 and in 
2008--as the basis for allocating the $30 million in compact impact 
grants among affected jurisdictions. Under their agreements, Census 
was reimbursed by Interior for both enumerations. Census and Interior 
officials did not retain a record of the cost of the 2003 snowball 
enumeration, but in 2011 the director of the 2003 effort estimated the 
cost at $400,000 to $500,000, including Census headquarters and field 
costs but excluding the cost of a final report. In 2008, the two- 
pronged approach cost approximately $1.3 million, including 
headquarters and field costs and the cost of final reporting.[Footnote 
27] 

U.S. Census Data Show Compact Migrants throughout U.S. Areas, with 
Growing Populations in Guam and Hawaii: 

Compact Migrants Reside throughout States and Territories: 

The combined data from Census' 2005-2009 ACS and the 2008 required 
enumerations in Guam and the CNMI estimated approximately 56,000 
compact migrants[Footnote 28]--nearly a quarter of all FAS citizens-- 
living in U.S. areas, with the largest populations in Guam and Hawaii. 
[Footnote 29] An estimated 57.6 percent of all compact migrants lived 
in affected jurisdictions: 32.5 percent in Guam, 21.4 percent in 
Hawaii, and 3.7 percent in the CNMI. According to ACS data, nine 
mainland states had estimated compact migrant populations of more than 
1,000.[Footnote 30] (See figure 2.) In comments on a draft of this 
report, the government of Arkansas stated that it had serious doubts 
about the accuracy of the ACS estimate for Arkansas shown in figure 2, 
particularly in comparison to the higher count implied by 2010 
decennial Census data and school enrollment data from Springdale, 
Arkansas. See appendix IV for a discussion of the differences between 
these data sources, and see appendix II for the varying estimates in 
Arkansas. 

Figure 2: Estimated Numbers of Compact Migrants in U.S. Areas, 2005- 
2009: 

[Refer to PDF for image: illustrated U.S. map] 

U.S. areas with an estimated 1000 or more FAS compact migrants: 

Guam[A]; 
Total-midpoint: 18,305; 
Total-90% confidence level, Low: 14,866; 
Total-90% confidence level, High: 21,744. 

Hawaii; 
Total-midpoint: 12,060; 
Total-90% confidence level, Low: 10,579; 
Total-90% confidence level, High: 13,541. 

California; 
Total-midpoint: 2,920; 
Total-90% confidence level, Low: 2,124; 
Total-90% confidence level, High: 3,716. 

Washington; 
Total-midpoint: 2,800; 
Total-90% confidence level, Low: 2,225; 
Total-90% confidence level, High: 3,375. 

Oregon; 
Total-midpoint: 2,210; 
Total-90% confidence level, Low: 1,713; 
Total-90% confidence level, High: 2,707. 

CNMI[A]; 
Total-midpoint: 2,100; 
Total-90% confidence level, Low: 1,589; 
Total-90% confidence level, High: 2,611. 

Utah; 
Total-midpoint: 1,630; 
Total-90% confidence level, Low: 766; 
Total-90% confidence level, High: 2,494. 

Oklahoma; 
Total-midpoint: 1,190; 
Total-90% confidence level, Low: 778; 
Total-90% confidence level, High: 1,602. 

Florida; 
Total-midpoint: 1,170; 
Total-90% confidence level, Low: 780; 
Total-90% confidence level, High: 1,560. 

Arkansas; 
Total-midpoint: 1,155; 
Total-90% confidence level, Low: 938; 
Total-90% confidence level, High: 1,372. 

Missouri; 
Total-midpoint: 1,090; 
Total-90% confidence level, Low: 824; 
Total-90% confidence level, High: 1,356. 

Arizona; 
Total-midpoint: 1,030; 
Total-90% confidence level, Low: 652; 
Total-90% confidence level, High: 1,408. 

Remaining states[B]; 
Total-midpoint: 8,680; 
Total-90% confidence level, Low: 7,517; 
Total-90% confidence level, High: 9,843. 

Sources: Map Resources (map); GAO analysis of a special Census 
tabulation of American Community Survey 2005-2009 data for U.S.states; 
Census tabulations of 2008 FAS migrant survey data for Guam and the 
CNMI. 

[A] The Guam and CNMI estimates are from the 2008 enumeration; 
remaining estimates are from the 2005-2009 ACS. 

[B] Census suppressed the estimated values of remaining states to 
protect the confidentiality of individual respondents; we do not know 
how many of the remaining states contain migrants. 

[End of figure] 

On the basis of these combined data, we estimate that approximately 68 
percent of compact migrants were from the FSM, 23 percent were from 
the Marshall Islands, and 9 percent were from Palau. According to 
these estimates, although the FSM produced the highest number of 
migrants, Marshallese predominated in Arizona, Arkansas, California, 
and Washington. 

See appendix III for Census's 2005-2009 ACS estimates of compact 
migrants by U.S. area and FAS of origin. 

Census has also published the 2010 decennial census counts of Pacific 
Islanders, with respondents identifying themselves by race, for the 50 
U.S. states. Decennial census data include published state-level 
information on the Marshallese population and will provide counts of 
ethnicities from the FSM and Palauans in the future. According to 
these data, there are more than 1,000 Marshallese identified by race 
in five states, with the largest number in Hawaii and Arkansas. See 
appendix IV for information on the Marshallese population gathered 
through the 2010 decennial census in the 50 states. 

Enumerations Show Growing Populations of Compact Migrants in Guam and 
Hawaii: 

Surveys that Interior conducted in affected jurisdictions from 1993 
through 2008 show growth in the compact migrant populations in Guam 
and Hawaii.[Footnote 31] In the CNMI, the compact migrant population 
declined between 2003 and 2008, mirroring a general decline in the 
CNMI population. (See figure 3.) 

Figure 3: Estimated Compact Migrant Population in Guam, Hawaii, and 
the CNMI, 1993-2008: 

[Refer to PDF for image: vertical bar graph] 

Year: 1993[A]; 
Guam: 5,160; 
Hawaii: [Empty]; 
CNMI: 751. 

Year: 1998[B]; 
Guam: 6,550; 
Hawaii: 5,509; 
CNMI: 1,755. 

Year: 2003; 
Guam: 9,831; 
Hawaii: 7,297; 
CNMI: 3,570. 

Year: 2008[C]; 
Guam: 18,305; 
90% confidence level, high: 21,744; 
90% confidence level, low: 14,866; 
Hawaii: 12,215; 
90% confidence level, high: 14,951; 
90% confidence level, low: 9,479; 
CNMI: 2,100; 
90% confidence level, high: 2,611
90% confidence level, low: 1,589. 

Source: GAO analysis of Census survey. 

[A] The Guam survey was conducted in 1992 and the CNMI survey in 1993; 
Hawaii was not surveyed at that time. The Palau compact did not enter 
into force until 1994; therefore, Palauans are not included in the 
1992 or 1993 totals. 

[B] Guam and Hawaii were surveyed in 1997, and the CNMI was surveyed 
in 1998. 

[C] Within the 90 percent confidence interval, the 2008 estimate for 
Guam ranges from 14,866 to 21,744; for Hawaii, from 9,479 to 14,951; 
and for the CNMI, from 1,589 to 2,611. Census did not use a 
probability sample for surveys prior to 2008; therefore, those surveys 
do not have an associated confidence interval. 

[End of figure] 

From 2003 through 2008, the percentage of the total compact migrant 
population grew in Guam and Hawaii. In 2008, compact migrants 
represented approximately 12 percent of the total population in Guam 
and one percent of the total population of Hawaii. (See figure 4.) 

Figure 4: Estimated Percentages of Total Populations of Guam, Hawaii, 
and the CNMI Who Are Compact Migrants, 1993-2008: 

[Refer to PDF for image: vertical bar graph] 

Year: 1993[A]; 
Guam: 3.6%; 
Hawaii: [Empty]; 
CNMI: 1.4%. 

Year: 1998[B]; 
Guam: 4.5%; 
Hawaii: 0.5%; 
CNMI: 2.7%. 

Year: 2003; 
Guam: 6.3%; 
Hawaii: 0.6%; 
CNMI: 5.5%. 

Year: 2008[C]; 
Guam: 11.6%; 
90% confidence level, high: 13.7%; 
90% confidence level, low: 9.4%; 
Hawaii: 0.9%; 
90% confidence level, high: 1.1%; 
90% confidence level, low: 0.7%; 
CNMI: 3.7%; 
90% confidence level, high: 4.6%
90% confidence level, low: 2.8%. 

Source: GAO analysis of Census survey. 

Notes: The 2003 and 2008 estimates of the total population of the 
affected jurisdictions are based on a linear interpolation of data 
from the 2000 and recently released 2010 decennial censuses. 1993 and 
1998 estimates of affected jurisdiction population are existing Census 
estimates. 

[A] The Guam survey was conducted in 1992 and the CNMI survey in 1993; 
Hawaii was not surveyed at that time. The Palau compact did not enter 
into force until 1994; therefore, Palauans are not included in the 
1992 or 1993 totals. 

[B] Guam and Hawaii were surveyed in 1997 and the CNMI in 1998. 

[C] Census did not use a probability sample for surveys prior to 2008; 
therefore, those surveys do not have an associated confidence interval. 

[End of figure] 

Compact Migrants Cited Several Reasons for Migration: 

Census's 2003 survey of compact migrants in the affected jurisdictions 
found that most migrated to the affected jurisdictions for employment 
or to accompany migrating relatives. Employment was the most common 
reason for migration in Guam and CNMI, followed by accompanying 
relatives. In Hawaii, slightly more migrants identified accompanying 
relatives than employment as their reason for migration. In Guam and 
the CNMI, less than 1 percent of migrants cited medical reasons for 
migration; in Hawaii, 10 percent cited medical reasons. 

Census's 2008 survey did not ask about reasons for migration. However, 
during our interviews in 2011, compact migrants and officials from FAS 
embassies and consulates identified employment opportunities, 
educational opportunities, accompanying relatives, and access to 
health care as reasons for migration, similar to the findings from 
Census's previous surveys. 

Enumeration Approach in 2008 and Preliminary Approach for 2013 Have 
Strengths and Limitations: 

Approach Used in 2008 Had Strengths and Limitations: 

The two-pronged 2008 enumeration, on which the current allocation of 
compact impact grants is based, had certain strengths and limitations. 
Strengths of the 2008 enumeration included its reliance on available 
data in Hawaii, lowering the enumeration's cost, and its use of a 
probability method in all jurisdictions that allows Census to 
statistically calculate the quality of the data and report margins of 
error for the enumerations in all three jurisdictions.[Footnote 32] 
Limitations of Census's approach for the 2008 enumeration included its 
use of two different methods and its use of data from two different 
time periods, both of which affect the perceived fairness and 
usefulness of the enumerations. In addition, data resulting from the 
2008 approach has limited comparability with data from the prior 
surveys and includes limited demographic information, limiting the 
usefulness of the 2008 data for purposes other than the required 
enumeration.[Footnote 33] 

* Use of two different methods. The data produced by block sampling in 
Guam and the CNMI and the ACS tabulations in Hawaii that were used for 
the 2008 enumeration are not fully comparable among the affected 
jurisdictions.[Footnote 34] 

* Use of data from different time periods. Because the 2008 
enumeration used data from two different time periods--2008 for Guam 
and the CNMI and 2005 to 2007 for Hawaii--the enumerations for the 
respective jurisdictions do not reflect the continuing migration to 
Hawaii after 2007 but do reflect such migration to Guam and the CNMI. 
[Footnote 35] The effect of the earlier time frame is to undercount 
the compact migrants in Hawaii relative to the counts in Guam and the 
CNMI. 

* Limited comparability with prior enumeration. The shift in 
approaches from prior enumerations to 2008 limits Interior's and 
affected jurisdictions' ability to draw inferences from trends in the 
data. Some differences in the counts for those years may be 
attributable to the change in methodology rather than changes in the 
populations. However, using the same methodology at different points 
in time does not guarantee comparability of data across time.[Footnote 
36] 

* Limited collection of demographic data. In 2008, Census did not 
collect information on characteristics of compact migrants in Guam and 
the CNMI beyond that required for the enumerations.[Footnote 37] 
Collected ACS demographic data on characteristics such as employment, 
income, and age distribution may not be statistically reliable for 
populations as small as that of compact migrants in Hawaii. The 
numbers of compact migrants found by the ACS in each year's Hawaii 
survey are very small. For example, the 2006 ACS identified, by place 
of birth and arrival after the compact's effective date, 55 persons 
from the FSM, 30 persons from the Marshall Islands, and 3 from Palau. 
The ACS for 2005-2007 identified a cumulative total of 295 compact 
migrants, from which Census estimated the total reported population. 

Affected Jurisdictions Opposed Change in Enumeration Methods for 2008: 

Affected jurisdictions expressed concerns about the potential accuracy 
and fairness of the 2008 enumeration approach. Guam, Hawaii, and CNMI 
officials expressed a preference for the snowball method that was used 
for the prior enumeration, stating that it was a more suitable 
approach to enumerating compact migrants. Further, though the snowball 
method used in the past had undercounted migrants, these officials 
were concerned that the 2008 approach would also miscount.[Footnote 
38] Both Guam and CNMI officials stated that the compact migrant 
population changed addresses frequently, potentially affecting the 
sampling methodology and leading to a miscount. Hawaii expressed 
concern that the use of ACS data for the state from earlier years 
would not reflect recent migration and, in contrast to the special 
survey to be conducted in Guam and the CNMI, would eliminate Hawaii's 
local input into the survey while permitting such input from Guam and 
the CNMI. However, Guam and the CNMI also stated that implementation 
of the survey was rushed and they had only limited opportunity to 
provide such input. In addition, Guam, Hawaii, and CNMI officials 
expressed concern that the approach chosen for 2008 would provide 
fewer demographic data. Led by the University of Hawaii, the Hawaii 
Governor's office prepared an unsolicited proposal to Interior to 
conduct a snowball survey in all three affected jurisdictions. 

Responding to the affected jurisdictions' concerns, Census officials 
stated that the snowball method was statistically insufficient and was 
unlikely to meet statistical survey criteria established by OMB in 
2006.[Footnote 39] These criteria require agencies initiating a new 
statistical survey to document the precision required of the estimates 
(e.g., the size of differences that need to be detected). 

Interior offered to adopt Hawaii's proposal if all affected 
jurisdictions agreed to it; however, Guam and the CNMI did not agree 
to the proposal. In addition, Interior cited Census's independence as 
an advantage of its conducting the enumerations. Officials in all 
three affected jurisdictions, however, remained dissatisfied with the 
2008 enumeration approach. (See appendix V for attributes of the 2008 
approach compared with the approach used for the prior enumeration.) 

Preliminary Approach for 2013 Also Has Strengths and Limitations: 

Although Interior has not yet selected an approach for its 2013 
enumeration of compact migrants in the affected jurisdictions, 
Interior and Census officials are discussing a preliminary approach 
that would have strengths and limitations similar to those we found in 
the 2008 approach.[Footnote 40] As of July 2011, according to Census 
officials, no agreement was in place for Census to conduct this work. 
However, according to both Interior and Census officials, if Interior 
employs Census for the 2013 enumeration, Census would again deploy a 
two-pronged approach, using the 2010 decennial census results for Guam 
and the CNMI and the ACS for Hawaii. Interior has not determined the 
cost of the preliminary approach or weighed its strengths and 
limitations. 

Our analysis shows that the strength of the preliminary 2013 approach 
would be its low cost; because it would draw solely from existing 
Census data, it would require no new data collection. However, it 
would have limitations similar to those we found in the 2008 approach, 
compromising both its fairness as a basis for distributing compact 
impact funds as well as the usefulness of the data it produces. 

* Use of two different methods. Using the counts provided through the 
full enumeration contained in the 2010 census in Guam and the CNMI 
produces single numbers for these jurisdictions.[Footnote 41] In 
Hawaii, use of the ACS would provide an estimated total based on a 
sample with calculated level of precision. 

* Use of data from different time periods. The preliminary approach 
would use data from April 1, 2010 for Guam and the CNMI and from 
multiple ACS monthly samples at different points in time for Hawaii. 

* Limited comparability with prior data. The change in enumeration 
method for Guam and CNMI would limit the comparability of the 2008 and 
2013 enumerations. 

* Limited collection of demographic data. Detailed demographic data 
could be produced for compact migrants in Guam and CNMI, because the 
2010 decennial census in those locations collected such data. However, 
as in 2008, demographic data from the ACS in Hawaii could lack 
statistical reliability because of the small number of migrants 
included in the ACS sample. 

In addition, the 2010 census and the ACS may provide different 
coverage of the compact migrant populations. The 2010 census 
collection followed a widespread campaign by Census and community 
groups to encourage participation, while the ACS collection efforts 
are not accompanied by this level of outreach.[Footnote 42] 

Estimates of Rising Compact Impact Costs Have Weaknesses, and Guidance 
on Impact Reporting Is Lacking: 

Guam and Hawaii Report Rising Costs, Primarily for Education and 
Health: 

For 2004 through 2010, the affected jurisdictions' reports to Interior 
show more than $1 billion in costs for services related to compact 
migrants.[Footnote 43] During that period, Guam's reported costs 
increased by nearly 111 percent, and Hawaii's costs increased by 
approximately 108 percent. The CNMI's reported costs decreased by 
approximately 53 percent, reflecting the decline in the CNMI compact 
migrant population. 

Figure 5 shows compact impact costs reported by the affected 
jurisdictions for 1996 through 2010. For more details, see appendix VI. 

Figure 5: Reported Compact Impact Costs, 1996-2010: 

[Refer to PDF for image: vertical bar graph] 

Dollars in millions: 

Year: 1996; 
Guam: $16.1; 
Hawaii: $6.4; 
CNMI: $11. 

Year: 1997; 
Guam: $19.1; 
Hawaii: $12.2; 
CNMI: $13.7. 

Year: 1998; 
Guam: $19.1; 
Hawaii: $12.4; 
CNMI: $15.1. 

Year: 1999; 
Guam: $19.0; 
Hawaii: $14.1; 
CNMI: $12.3. 

Year: 2000; 
Guam: $24.5; 
Hawaii: $17.5; 
CNMI: $9.2. 

Year: 2001; 
Guam: $23.4; 
Hawaii: $21.5; 
CNMI: $4.6. 

Year: 2002; 
Guam: $23.3; 
Hawaii: $30.4; 
CNMI: $4.6. 

Year: 2003; 
Guam: $30.9; 
Hawaii: $47.4; 
CNMI: $4.2. 

Year: 2004; 
Guam: $31.2; 
Hawaii: $55.3; 
CNMI: $10.0. 

Year: 2005; 
Guam: $28.2; 
Hawaii: $66.9; 
CNMI: $10.3. 

Year: 2006; 
Guam: $42.2; 
Hawaii: $81.0; 
CNMI: $9.7. 

Year: 2007; 
Guam: $47.3; 
Hawaii: $90.8; 
CNMI: $8.6. 

Year: 2008; 
Guam: $53.3; 
Hawaii: $101.0; 
CNMI: $8.2. 

Year: 2009; 
Guam: $58.7; 
Hawaii: $118.8; 
CNMI: $4.0. 

Year: 2010; 
Guam: $65.7; 
Hawaii: $114.9; 
CNMI: $4.7. 

Source: GAO analysis of affected jurisdictions’ reported compact 
impact costs. 

Notes: For 1986 through 1995, Guam reported total costs of $60.6 
million, Hawaii reported total costs of $23.4 million, and the CNMI 
estimated total costs at $43.7 to $71.7 million. From 1996 through 
2003, Guam reported total costs of $175.3 million, Hawaii $162 
million, and the CNMI $74.7 million. 

[End of figure] 

The reported costs are in nominal dollars, unadjusted for inflation. 

The affected jurisdictions reported impact costs for educational, 
health, public safety, and social services. Education accounted for 
the largest share of reported expenses in all three jurisdictions, and 
health care costs accounted for the second-largest share overall. (See 
table 1.) 

Table 1: Affected Jurisdictions' Reported Compact Impact, by Sector, 
2004-2010: 

Sector: Educational services; 
Guam: $201,080,392; 
Hawaii: $291,063,024; 
CNMI: $25,426,059; 
Total: $517,569,475. 

Sector: Health services; 
Guam: $65,374,486; 
Hawaii: $237,888,693; 
CNMI: $10,700,277; 
Total: $313,963,456. 

Sector: Public safety services; 
Guam: $55,561,983; 
Hawaii: $7,641,537; 
CNMI: $17,862,038; 
Total: $81,065,558. 

Sector: Social services; 
Guam: $4,532,431; 
Hawaii: $92,159,026; 
CNMI: $1,527,730; 
Total: $98,219,187. 

Sector: Total; 
Guam: $326,549,292; 
Hawaii: $628,752,280; 
CNMI: $55,516,104; 
Total: $1,010,817,676. 

Source: GAO analysis of affected jurisdictions' compact impact reports 
for 2004 through 2010. 

Note: The reported costs are in nominal dollars, unadjusted for 
inflation. 

[End of table] 

Our analysis of data in affected jurisdictions' impact reports for 
2004 through 2010 found that, reflecting the growing numbers of 
compact migrants, annual costs for educational services across all 
jurisdictions increased from approximately $46 million to $89 million, 
or by 93 percent. Annual costs for health services across all 
jurisdictions increased from approximately $33 million to $54 million, 
or by 66 percent. 

The affected jurisdictions' impact reports, numerous studies, federal 
and state officials, and officials from affected jurisdictions have 
identified several other factors, in addition to growing migrant 
populations, that contribute to the cost of providing public services 
to compact migrants.[Footnote 44] 

* Educational services. Compact migrant school children generally lag 
academically owing to (1) poor-quality schools in the FAS; (2) limited 
language skills and experience with a school environment; and (3) 
difficulties in involving parents in their children's education, due 
to language barriers.[Footnote 45] Various officials from affected 
jurisdictions, Interior, and service providers said these factors 
increase the resources required to provide educational services to 
compact migrants relative to other students.[Footnote 46] 

* Health services. FAS citizens have high rates of obesity; diabetes; 
hypertension; cardiovascular disease; and communicable diseases such 
as tuberculosis, Hansen's disease, and sexually transmitted 
diseases.[Footnote 47] The Department of the Interior's Inspector 
General has reported on inadequate health care systems in the FAS, 
which can lead to the prevalence of these health issues among FAS 
citizens. These health factors also lead some FAS citizens to migrate 
in order to gain access to the U.S. health care system. In U.S. areas, 
compact migrants' low household incomes may lead many migrants to rely 
on public health services.[Footnote 48] 

* Social services. Like many other migrant populations, compact 
migrants often face challenges related to homelessness, reliance on 
public housing, and crowded living conditions. 

Compact Migrants Are Ineligible for Several Federal Programs: 

Various officials in Guam and Hawaii also cited compact migrants' 
limited eligibility for a number of federal programs, particularly 
Medicaid, as a key contributor to the cost of compact migration borne 
by the affected jurisdictions. Table 2 shows compact migrants' 
eligibility status for selected federal benefit programs. 

Table 2: Eligibility Status of Compact Migrants for Selected Federal 
Benefit Programs: 

Program: Social Security Old Age, Survivors, and Disability Insurance; 
Federal eligibility status[A]: Eligible[B]. 

Program: Social Security Supplemental Security Income (SSI); 
Federal eligibility status[A]: Generally ineligible[C]. 

Program: Medicaid; 
Federal eligibility status[A]: Generally ineligible[D]. 

Program: Emergency Medicaid; 
Federal eligibility status[A]: Eligible. 

Program: Medicare; 
Federal eligibility status[A]: Eligible[B]. 

Program: Children's Health Insurance Program (CHIP); 
Federal eligibility status[A]: Generally ineligible[D,E]. 

Program: Temporary Assistance for Needy Families (TANF); 
Federal eligibility status[A]: Ineligible. 

Program: Supplemental Nutrition Assistance Program (SNAP); 
Federal eligibility status[A]: Ineligible. 

Program: School Lunch Programs; 
Federal eligibility status[A]: Eligible. 

Program: Section 8 Housing Federal Rent Subsidies for Eligible 
Families; 
Federal eligibility status[A]: Eligible. 

Source: GAO analysis of federal benefits program laws and regulations. 

Note: This information applies to compact migrants who are not U.S. 
citizens. 

[A] Eligibility status shown is based solely on compact migrant 
status. Compact migrants may be eligible for some benefits for other 
reasons, such as membership in the military. 

[B] Eligibility is based on work history. 

[C] A compact migrant is eligible for SSI benefits if he or she was 
receiving such benefits on August 22, 1996. 

[D] The Children's Health Insurance Program Reauthorization Act of 
2009 (CHIPRA), Pub. L. No. 111-3, permits states to cover certain 
children and pregnant women in both Medicaid and the Children's Health 
Insurance Program (CHIP) who are "lawfully residing in the United 
States"--a definition that includes compact migrants. 

[E] States may also choose to extend CHIP eligibility to unborn 
children and provide prenatal care and delivery. See 67 Fed. Reg. 
61956 (Oct. 2, 2002). 

[End of table] 

In some cases, affected jurisdictions have provided services for 
compact migrants at local expense that are similar to those available 
to U.S. citizens. For example, Guam, Hawaii and the CNMI provide 
funding for medical services that, prior to 1996, were available 
through Medicaid to low-income non-U.S. citizen compact migrants. 
[Footnote 49] U.S.-born children of compact migrants are eligible as 
citizens for the benefits available to them as U.S. citizens. 

Compact Impact Estimates Have a Number of Weaknesses: 

We identified a number of weaknesses in affected jurisdictions' 
reporting of compact impacts to Interior from 2004 through 2010 
related to accuracy, adequacy of documentation, and 
comprehensiveness.[Footnote 50] Examples of such weaknesses include 
the following (see appendix VI for more details). 

Accuracy: 

* Definition of compact migrants. For several impact reports that we 
examined, the reporting local government agencies (state and 
territorial agencies in the affected jurisdictions) did not define 
compact migrants according to the criteria in the amended compacts 
enabling legislation when calculating service costs.[Footnote 51] For 
instance, some agencies defined and counted compact migrants using the 
proxy measures of ethnicity, language, or citizenship rather than the 
definition in the amended compacts' enabling legislation. Using 
ethnicity or language as a proxy measure could lead to overstating 
costs, since neither measure would exclude individuals who came to the 
jurisdiction prior to the compact, while using citizenship as a proxy 
measure could lead to understating costs, since it would exclude U.S.- 
born children of compact migrants.[Footnote 52] 

* Federal funding. States and territories receive federal funding for 
specific programs that offsets a portion of the costs of providing 
services to compact migrants. However, two of the three affected 
jurisdictions' public school systems and health agencies did not 
account for these offsets in their impact reporting, thus overstating 
reported compact impact costs. 

* Revenue. Multiple local government agencies that receive revenues, 
such as user fees, associated with services provided to compact 
migrants did not consider them in their compact impact reports, thus 
overstating reported costs. 

* Capital costs. Many local government agencies did not include 
capital costs in their impact reporting. Capital costs entail, for 
example, providing additional classrooms to accommodate an increase in 
students or additional health care facilities. In cases where compact 
migration has resulted in the expansion of facilities, agencies 
understated compact migrant impact by omitting these costs. 

* Per person costs. A number of local government agencies used an 
average per-person service cost for the jurisdiction rather than 
specific costs associated with providing services to compact migrants. 
Hawaii reported in 2008 that several costly diseases are 
overrepresented within the compact migrant population. Using the 
average cost may either overstate or understate the true cost of 
service provision.[Footnote 53] In some cases--for example, the 
provision of health services--the service cost for each compact 
migrant could be determined. However, a number of agencies apply a 
range of approaches, such as using the simple average cost (e.g., cost 
per student) or factoring in higher costs if additional or more costly 
services are used. 

* Discretionary costs. Some compact impact costs local government 
agencies reported were for benefits or services provided at the 
discretion of the affected jurisdiction. 

* Data reliability. One local government agency used data on compact 
migrants that were found to be in error in a subsequent compilation of 
their impact reporting and caused an overstatement of total costs in 
its impact reporting. 

Documentation Adequacy: 

A number of local government agencies did not disclose their 
methodology, including any assumptions, definitions, and other key 
elements, for developing impact costs making it difficult to evaluate 
reported costs. 

Comprehensiveness: 

For those years when the affected jurisdictions submitted impact 
reports to Interior, not all local government agencies in the 
jurisdictions included all compact impact costs for those years. 
Between the affected jurisdictions the scope of reporting differed, 
with one jurisdiction not reporting cost related to police services. 

Existing Compact Impact Reporting Guidelines Have Gaps and Generally 
Are Not Used: 

Guidelines that Interior developed in 1994 for compact impact 
reporting for Guam and the CNMI do not adequately address certain 
concepts key to reliable estimates of impact costs. Developed in 
response to a 1993 recommendation by the Interior Inspector General, 
[Footnote 54] the guidelines suggest that impact costs in Guam and the 
CNMI should, among other concepts, (1) exclude FAS citizens who were 
present prior to the compacts, (2) specify omitted federal program 
costs, and (3) be developed using appropriate methodologies. However, 
the 1994 guidelines do not address certain concepts, such as 
calculating revenue received from providing services to compact 
migrants; including capital costs; and ensuring that data are reliable 
and reporting is consistent. 

Several Hawaii and CNMI officials from the reporting local government 
agencies we met with, as well as Interior officials, were not aware of 
the 1994 guidelines and had not used them. Officials at the Guam 
Bureau of Statistics and Plans, which was in possession of the 
guidelines, said that the bureau attempts to adhere to them when 
preparing compact impact cost estimates. The bureau does not provide 
these guidelines in its annual letter to the agencies when requesting 
compact impact costs since the agencies do not submit their reports 
for Interior directly. The bureau said it applies the guidelines to 
the data it receives from the agencies prior to submitting the final 
report to Interior. However, we found some cases where the bureau and 
local Guam agencies did not follow the guidelines. 

Interior's Reporting of Compact Impacts to Congress Has Been Limited: 

Interior's reporting to Congress on compact impacts reported by the 
affected jurisdictions has been limited. The amended compacts' 
enabling legislation requires Interior, if it receives compact impact 
comments from the Governor of an affected jurisdiction by February 1, 
to submit a report with specific required elements on compact impact 
to Congress no later than May 1 of that year.[Footnote 55] As of 
August 2011, Interior had submitted one required report to Congress in 
2010 but had not submitted any reports in 2004 through 2009, although 
at least one affected jurisdiction had reported compact impacts to 
Interior in each of those years.[Footnote 56] Although Interior 
officials stated they were preparing their 2011 congressional report, 
as of August 2011 it had not been submitted. 

Interior's 2010 report did not address all elements required by the 
amended compacts' enabling legislation: 

* Interior's report lacked information from the Guam and Hawaii 
governors' compact impact reports regarding increasing compact migrant 
costs, the types of services being used, and the associated costs for 
each local government agency. Interior's report did not analyze the 
impact cost information provided by the two governments. However, 
Interior noted that the affected jurisdictions' compact impact reports 
do not calculate compact migrants' contributions. 

* Interior's report did not state its views on recommendations for 
corrective action, such as Hawaii's suggestion to authorize compact 
migrant eligibility for all federal assistance programs to reduce 
impact. However, Interior relayed requests from the governors of Guam 
and Hawaii for additional funds and provided a summary of Interior's 
compact impact funding provided to Guam and Hawaii. 

In August 2011, Interior reminded affected jurisdictions of their 
option to submit annual compact impact reports and identified a point 
of contact at Interior to which the reports may be submitted. Interior 
also noted that it is currently developing a process to ensure timely 
submissions to Congress. 

Data Quantifying Compact Migrant Participation in Local Economies Are 
Limited: 

Compact migrants participate in local economies through their 
participation in the labor force, payment of taxes, consumption of 
local goods and services, and receipt of remittances. Previous compact 
migrant surveys estimated compact migrants' participation in the labor 
force, but existing data on other compact migrant contributions such 
as tax revenues, local consumption, or remittances are not available 
or sufficiently reliable to quantify their effects. 

Labor Market: 

According to data from the 2003 Surveys of Micronesian Migrants, the 
majority of compact migrants participated in CNMI's and Guam's labor 
force and over 40 percent participated in Hawaii's labor force. 
[Footnote 57] However, compact migrants generally participate in the 
labor force at lower rates than the general population. The 2003 data 
also showed that compact migrants from the Marshall Islands generally 
had lower labor force participation rates than compact migrants from 
the FSM and Palau. 

Compact migrant workers generally work in low-skilled 
occupations.[Footnote 58] According to data from the 2003 survey, the 
majority of compact migrant workers work in the private sector as (1) 
operators, fabricators, and laborers; (2) service workers; and (3) 
technical, sales, and administrative support. Guam and Hawaii do not 
have more recent data on compact migrant workforce participation, but 
CNMI Department of Finance data show that, on average, compact 
migrants comprised 2.3 percent of the CNMI workforce from 2004 through 
2009 and had income 14 percent higher than other workers.[Footnote 59] 
Persons born in the FAS may also serve in the U.S. armed services and, 
as of August 2011, 381 were serving on active duty.[Footnote 60] 

Taxes: 

Compact migrants participate in local economies through taxation, but 
reliable data quantifying their effect are not available. Guam and 
Hawaii do not collect data on the ethnicity of taxpayers or other 
information that could be used to disaggregate the taxes paid by 
compact migrants from overall receipts.[Footnote 61] However, for 
Guam, our estimates show that compact migrant workers paid $971 less 
(68 percent less) per capita in taxes than other workers in 
2009.[Footnote 62] Approximately 60 percent of this difference results 
from compact migrant workers' being much less likely to be employed in 
Guam's higher paying public sector. The remaining difference results 
from the higher number of exemptions that compact migrant workers 
could claim, on average, for family members when filing 
taxes.[Footnote 63] Alone among affected jurisdictions, the CNMI 
collects data on citizenship that could be used to identify the taxes 
paid by compact migrants. However, the data provided by the CNMI 
include only the amount of taxes withheld and not the amount 
ultimately paid. These data may overestimate the amount of taxes paid, 
since a portion of taxes withheld may be returned to the taxpayer. 

Consumption And Remittances: 

Compact migrants contribute to the local economy by consuming local 
goods and services and by spending remittances that they receive from 
their home islands in affected jurisdictions. Their total consumption 
and economic effect may be reduced if they remit some of their income 
to their home islands. Data from 1998 suggest that compact migrants 
generally consume less of their income than does the general 
population; however, since that time, no data quantifying consumption 
by compact migrants has been published.[Footnote 64] Compact migrants 
we met with confirmed that they send remittances to their home 
islands; however, estimates and methodologies for remittances have 
many limitations and vary significantly across sources, calling their 
reliability into question.[Footnote 65] 

Interior Grants Only Partially Address Compact Impact: 

Compact Impact Grants Have Addressed Some Reported Costs: 

From fiscal years 2004 through 2010, the $30 million in annual compact 
impact grants, which Interior has awarded in accordance with the 
enumerations of compact migrants, have addressed a portion of each 
jurisdiction's reported impact costs. Of the $210 million in impact 
grants, approximately $102 million was provided to Guam, $75 million 
to Hawaii, and $33 million to the CNMI (see figure 6). In their 
compact impact reports to Interior, the governors of Guam and Hawaii 
have highlighted the gaps between their reported impact costs and the 
amounts of the compact impact grants, requesting that the federal 
government provide additional support. 

Figure 6: Comparison of Compact Impact Costs Reported by Affected 
Jurisdictions and Compact Impact Grants Awarded by Interior, 2004-2010: 

[Refer to PDF for image] 

Dollars in millions: 

Guam: 

Cost Reported: 
Education: $ 201.1; 
Health: $65.4; 
Public Safety: $55.6; 
Social Services: $4.5; 
Infrastructure: $0. 

Grants Awarded: 
Education: $ 41.8; 
Health: $48.7; 
Public Safety: $7.81; 
Social Services: $3.5; 
Infrastructure: $0.5. 

Hawaii: 

Grants Awarded: 
Education: $ 291.1; 
Health: $237.9; 
Public Safety: $7.6; 
Social Services: $92.2; 
Infrastructure: $0. 

Compact Impact Awarded; 
Education: $0; 
Health: $74.6; 
Public Safety: $0; 
Social Services: $0; 
Infrastructure: $0. 

CNMI: 

Cost Reported: 
Education: $ 25.4; 
Health: $10.73; 
Public Safety: $17.9; 
Social Services: $1.5; 
Infrastructure: $0. 

Grants Awarded: 
Education: $ 9.2; 
Health: $13.2; 
Public Safety: $9.6; 
Social Services: $1.0; 
Infrastructure: $0. 

Source: GAO analysis of affected jurisdictions’ compact impact costs 
reported and Interior’s compact impact grants awarded. 

Notes: Reported costs and grant amounts are nominal, unadjusted for 
inflation. 

Limitations in affected jurisdictions' reported compact impact cost 
data affect the accuracy of affected jurisdictions reported costs as 
noted elsewhere in this report. 

[End of figure] 

Most Compact Impact Grants Have Supported Affected Jurisdictions' 
Budgets, Projects, and Purchases: 

Interior has approved affected jurisdictions' applications for compact 
impact grants to be used for general support of local budgets, 
projects, and for specific departmental purchases in the areas of 
health, education, public safety, and social services. 

* Guam. The largest annual compact impact grants to Guam in fiscal 
years 2005 through 2010 supported public school construction and 
maintenance.[Footnote 66] Most other compact impact grants to Guam 
funded health and public safety purchases, such as the purchase or 
renovation of facilities, emergency vehicles, and medical supplies, 
among many others. 

* Hawaii. All compact impact grants to Hawaii in fiscal years 2004 
through 2010 were provided to its Department of Human Services to 
offset the cost of state-funded medical services. 

* CNMI. Compact impact grants to the CNMI in fiscal years 2004 through 
2010 supported the operations of several CNMI government departments, 
such as the departments of public health and public safety, and the 
public school system. 

See appendix VII for a description of Interior's grant reviews and a 
list of compact impact grants to the affected jurisdictions from 
fiscal years 2004 to 2011.[Footnote 67] 

Government Officials, Service Providers, and Compact Migrants 
Suggested Approaches to Directly Address Challenges Related to Compact 
Migration: 

Compact migrants confront complex challenges related to the compact 
migrants' unfamiliarity with local language and culture, limited job 
skills, and difficulty in accessing available services, according to 
various government officials, services providers, and compact 
migrants. Compact impact grants are generally not used to directly 
target these complex challenges. However, a report by the Hawaii 
Compacts of Free Association Taskforce released in 2008 recommended a 
review of the allocation and use of compact grants that the state 
received from Interior to determine whether there is a way to spend 
compact impact grants that would have a more effective long-term 
impact.[Footnote 68] Officials, providers, and migrants identified the 
following needs: 

Language and cultural assistance. Guam education, health, and social 
service officials reported, among other challenging cultural gaps 
facing arriving migrants, the need for interpreters to assist patients 
and families. Hawaii health providers noted that language and cultural 
barriers compromise care delivery. In addition, the Hawaii Taskforce 
report identified a need to develop translation and interpreter 
resources. A number of compact migrants in Guam and Hawaii identified 
language and cultural issues as a source of difficulty in using 
government services and identified a need for translators and language 
tutors. 

Job training. The Governor of Guam noted that FSM migrants in Guam 
face challenges due to their lack of job skills and education. Various 
members of the compact migrant community in Hawaii also cited lack of 
job skills as a challenge and said that job training is needed to help 
migrants gain employment. 

Access to basic services. Hawaii officials identified lack of 
coordination of services as a challenge. Various FAS officials noted 
that their citizens are at times frustrated in their attempts to 
obtain basic documents such as social security numbers and driver's 
licenses from officials who are unaware of the compact provisions for 
compact migrants. In addition, several compact migrants in Hawaii 
noted that compact migrants are often unaware of available benefits. 
[Footnote 69] 

To more directly address these needs, various government officials, 
service providers, and compact migrants suggested the establishment of 
centers offering multiple services to migrants. 

* In Guam, the Center for Micronesian Empowerment provides culture, 
language, and job skills training, as well as help in finding 
employment, to both arriving and resident compact migrants.[Footnote 
70] According to one of the center's founders, the language and 
cultural training has reduced employee attrition in companies that 
hire the trainees, and migrants who receive job skills training are 
almost guaranteed to find employment. Guam officials also noted that 
Interior grants had previously funded another resource center for FAS 
citizens that supported migrant efforts to assimilate and provided 
outreach and services to newly arriving migrants.[Footnote 71] 

* The Hawaii Taskforce report recommended the establishment of 
multipurpose cultural outreach service centers or mobile service 
delivery centers, among other options, to standardize service delivery 
processes and promote accessibility. 

* A senior official at the Hawaii State Department of Health advocated 
a "one-stop" service center approach for migrants with medical and 
other government services, with staff who can assist with language and 
cultural issues. Kokua Kalihi Valley, a community nonprofit in Hawaii, 
includes elements of such an approach, providing health, social, and 
youth services, among others, to compact migrants.[Footnote 72] 

* Several compact migrants in Hawaii suggested the establishment of a 
community center to help people adjust and acclimate--for example, by 
teaching them how to work with schools and access services. 

Sector Grants to the FSM and the Marshall Islands Indirectly Address 
Compact Impact: 

Sector grants awarded in fiscal years 2004 through 2010 may have 
helped mitigate compact impact by supporting the health and education 
sectors and, in some instances, directly targeted issues related to 
compact impact in the affected jurisdictions. In 2001, we reported 
that targeting assistance to the health and education sectors in the 
FSM and the Marshall Islands might lessen compact migration and its 
impact in the affected jurisdictions.[Footnote 73] For example, better 
education systems in the FSM and the Marshall Islands might reduce the 
motivation to migrate and enable those who do migrate to better 
succeed in U.S. schools. Also, targeting health spending where health 
services are limited might reduce the number of citizens who travel to 
the United States seeking medical care. Further, programs aimed at 
improving the health status of FAS citizens might reduce the impact of 
migrating citizens on the U.S. health care system. 

Under the amended compacts, the U.S.-Micronesia and U.S.-Marshall 
Islands joint management committees, chaired by Interior, annually 
review and approve sector grants that allocate funds primarily for 
education, health, and infrastructure. The amended compacts and 
related agreements outline the joint management committees' 
responsibilities as including allocating sector grants and 
recommending ways to increase the effectiveness of sector grant 
assistance. Based on the joint management committees' annual approval 
of sector grants, Interior has made available approximately $808 
million in sector grant funds in fiscal years 2004 through 2010. 
[Footnote 74] (See table 3 for sector grant allocations approved for 
fiscal year 2011.) 

Table 3: Sector Grant Awards in the FSM and the Marshall Islands, 
Fiscal Year 2011: 

Sectors: Education; 
FSM: $28,376,673; 
Marshall Islands: $11,839,151. 

Sectors: Health; 
FSM: $21,003,759; 
Marshall Islands: $6,834,858. 

Sectors: Infrastructure; 
FSM: $19,469,685; 
Marshall Islands: $11,696,314. 

Sectors: Other; 
FSM: $7,052,448; 
Marshall Islands: $5,800,115. 

Sectors: Total; 
FSM: $75,902,565; 
Marshall Islands: $36,170,438. 

Source: U.S. Department of the Interior, Office of Insular Affairs. 

[End of table] 

In allocating sector grants for fiscal years 2004 through 2010, the 
joint management committees did not formally address the needs of 
compact migrants or their impact on U.S. states and territories, 
according to Interior officials. In 2011, the committees formally 
placed compact impact on their annual meeting agendas; however, as of 
September 2011 they had not allocated 2012 sector grant funding to 
directly address issues that concern the compact migrants or the 
affected jurisdictions. 

The amended compacts indicate that the sector grants are to be used 
for sectors such as education, health care, the environment, public 
sector capacity building, and private sector development in the FSM 
and Marshall Islands but may be used for other sectors as mutually 
agreed, with priorities in the education and health care sectors. We 
found some examples of grants that directly address compact migrants' 
needs in affected jurisdictions and thus respond to some of the 
affected jurisdictions' concerns. 

* For fiscal years 2010 and 2011, three of the four states of the FSM 
agreed to use a total of approximately $842,000 of supplemental 
education grants to fund the Center for Micronesian Empowerment, which 
assists Micronesians in Guam with language and culture training, 
developing job skills, and finding employment. 

* For fiscal years 2009 and 2010, Interior awarded approximately $3.4 
million in health sector grants to the FSM and the Marshall Islands to 
address an outbreak of multidrug-resistant tuberculosis--a public 
health concern and a costly communicable disease that has occurred 
among migrants in the affected jurisdictions. 

During our visits to the affected jurisdictions in February 2011, the 
Governor of Guam identified a need to use sector grants in the FSM to 
improve education and health services to reduce compact impact in 
Guam, noting that he and the President of the FSM had discussed ways 
to work together to improve assimilation of migrants from the FSM in 
Guam. FSM migrants in Guam identified a need for cultural education 
and job training at home before citizens migrate to the United States. 
In Hawaii, officials identified the need to address health and social 
issues in the FSM and the Marshall Islands to better prepare FAS 
citizens considering migration and reduce the need for migrants to 
seek health and social services in Hawaii. In addition, compact 
migrants in Hawaii suggested that U.S. grant funds currently going to 
the FSM and the Marshall Islands be used to establish a compact 
migrants' cultural center in Hawaii. 

In May 2011, Members of Congress wrote to Interior and the Department 
of State asking that a portion of sector grants be used to fund a 
program to prepare FAS citizens for migration and to establish and 
operate dialysis treatment facilities in the FSM and the Marshall 
Islands so that patients will not seek treatment in the United States. 
In their annual meetings held in August and September of 2011, both 
joint management committees formally placed compact impact and fiscal 
year 2012 sector grants on their agendas, but neither committee 
allocated sector grants that directly address compact migration. 

Conclusions: 

Although the compact migrant population represents a tiny fraction of 
migrants in the United States, the population can have significant 
impacts on the U.S. communities where they reside. To help defray 
costs of providing services to compact migrants, Congress has 
appropriated compact impact funds that Interior allocates to the 
affected jurisdictions in proportion to the required periodic 
enumerations of compact migrants. However, developing a cost-effective 
enumeration approach that is fair, is accepted as credible by affected 
jurisdictions, and produces additional demographic data remains a 
challenge. Thorough consideration of the strengths, limitations, and 
costs of the preliminary approach for the 2013 enumeration, as well as 
the concerns of affected jurisdictions, would enhance Interior's 
ability to select a credible and reliable approach. 

Although the affected jurisdictions have reported rising costs of 
addressing compact migrants' needs for health, education, and social 
services, the jurisdictions' estimates of these costs have weaknesses 
that affect their reliability. Moreover, Interior's 1994 guidelines 
for reporting compact impact do not address certain concepts, such as 
defining compact migrants and calculating revenues, that are essential 
for reliable estimates of impact costs. Providing more rigorous 
guidelines to the affected jurisdictions that address concepts 
essential to producing reliable impact estimates and promoting their 
use for compact impact reports would increase the likelihood that 
Interior can provide reliable information on compact impacts to 
Congress. 

Interior's compact impact grants have generally been used for affected 
jurisdictions' budget support, projects, and purchases in the areas of 
education, health, and public safety. Meanwhile, government officials, 
service providers, and compact migrants noted the complex challenges 
confronting both service providers and migrants and suggested 
approaches to directly address these challenges. For example, centers 
offering multiple services could address migrants' needs for basic 
services as well as facilitate provision of services and improve 
migrants' access. One affected jurisdiction also noted the need to 
review the allocation and uses of the grants to determine whether they 
could be spent in a way that would increase their long-term 
effectiveness. Given that compact impact grants only partially offset 
the affected jurisdictions' reported rising impact costs, Interior 
working with the affected jurisdictions to identify alternative uses 
of the grants could more effectively address compact impact. 

Available data suggest that about 56,000 citizens of the FSM, the 
Marshall Islands, and Palau--nearly a quarter of all FAS citizens-- 
reside in the United States and its territories under provisions of 
the U.S. compacts with those countries. In Guam and Hawaii, officials 
have advocated the use of sector grants to reduce the impact of 
compact migration by improving education, health, and social services 
in the FSM and the Marshall Islands, and compact migrants cited the 
need for assistance in adapting to life after migration. The joint 
U.S. - FSM and U.S. - Marshall Islands committees' allocations of 
sector grants since 2003 have supported the health and education 
sectors in the FSM and the Marshall Islands and may indirectly help to 
mitigate compact impact in the affected jurisdictions. The committees 
have included compact impact on their recent agendas; however, they 
have not yet considered potential uses of the grants to directly 
address the issues that concern compact migrants or the affected 
jurisdictions. 

Recommendations for Executive Action: 

We recommend that the Secretary of the Interior take the following 
four actions: 

* In order to select the most appropriate approach for its next 
enumeration of compact migrants, fully consider the strengths and 
limitations of its preliminary approach for 2013, weighing the cost of 
the approach with the need for data that will be fair as well as 
useful to the affected jurisdictions. 

* In order to strengthen its ability to collect, evaluate, and 
transmit reliable information to Congress, disseminate guidelines to 
the affected jurisdictions that adequately address concepts essential 
to producing reliable impact estimates, and call for the affected 
jurisdictions to apply these guidelines when developing compact impact 
reports. 

* In order to promote the most effective use of compact impact grants, 
work with the affected jurisdictions to evaluate the current use of 
grant funds and consider alternative uses of these grants to reduce 
compact impact. 

* In order to help mitigate compact impact and better assist FSM and 
Marshall Islands citizens who migrate to the United States, work with 
the U.S.-FSM and U.S.-Marshall Islands joint management committees to 
consider uses of sector grants that would address the concerns of FSM 
and Marshallese migrants and the affected jurisdictions. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of the Interior; 
the Department of State; the Census Bureau; and the governments of 
Guam, Hawaii, the CNMI, Arkansas, the FSM, Marshall Islands, and Palau 
for review. All except the Department of State provided written 
comments, which we have summarized below with our responses. See 
appendixes VIII through XVI for reproductions of the comments, along 
with our detailed responses. 

Comments from U.S. Agencies: 

Department Of The Interior: 

Interior generally agreed with our findings and the recommendations 
that it fully consider the strengths and limitations of enumeration 
approaches and that it disseminate guidelines on impact estimates. 

However, Interior disagreed with our recommendation that it work with 
the affected jurisdictions to evaluate the use of compact impact grant 
funds and consider alternative uses. Interior stated that the amended 
compacts' enabling legislation authorizes broad uses of compact impact 
grants and that it has chosen to respect the funding priorities of the 
governors. Further, Interior stated that it did not believe that 
practical gains can be made by proposing alternatives. We believe 
Interior should not rule out the possibility of practical gains 
through a consideration of alternate uses of the grant funds. During 
our review, government officials and service providers suggested 
alternative uses of compact impact funding that may more directly 
address compact impact, such as measures to reduce certain health 
costs through the provision of preventive care. The governors of Guam 
and the CNMI agreed with this recommendation, and the governor of 
Hawaii noted that ideas to increase long-term capacity or efficiency 
of resources could be of great benefit to the affected jurisdictions. 
We retain our recommendation for Interior to work with governors to 
evaluate their current use of funds and to consider alternative uses. 

Interior agreed with our recommendation that it work with the U.S.-FSM 
and U.S.-Marshall Islands joint management committees to consider uses 
of sector grants that would address the concerns of compact migrants 
and the affected jurisdictions, subject to the funds being used within 
the FAS. However, Interior stated that our draft report implied that 
compact sector grant funds should be shifted from providing assistance 
to the FAS governments to providing assistance to FAS citizens living 
in the affected jurisdictions, an action that Interior sees as 
inconsistent with the compacts and their enabling legislation. We 
agree with Interior that compact sector grants are to support the 
governments of the FSM and the Marshall Islands by providing grant 
assistance to be used in certain sectors such as education and health 
care, or for other sectors as mutually agreed. We expect that compact 
sector grant awards will be provided consistent with the terms of the 
compacts and the amended compacts' enabling legislation; we do not 
intend to imply that funds should be shifted from FAS governments to 
FAS migrants. In response to Interior's concern, we clarified that our 
findings and recommendation highlight the opportunity for the joint 
management committees to consider the use of sector grants to the FSM 
and Marshall Islands in ways that address the concerns of FAS 
citizens--whether they are in the FAS or in U.S. areas--and the 
concerns of the affected jurisdictions. The recommendation supports 
consideration of the use of sector grants in ways that respond to the 
concerns of FSM and Marshall Islands migrants and the affected 
jurisdictions. 

Census Bureau: 

Census did not comment on our report's recommendations but offered a 
number of largely technical comments on our findings, which we have 
addressed as appropriate. Census disagreed with our assessment of the 
limitations of the 2008 enumeration methodologies. However, our 
findings indicate that the 2008 Guam and CNMI surveys are not 
comparable with the ACS estimates for Hawaii in terms of their 
sampling methods and reporting period. In addition, as our report 
notes, migration is continuing, and Hawaii ACS data does not include 
nearly a year of additional migration that may be captured in the Guam 
and CNMI totals. Regarding its varying estimates of compact migrants 
in Arkansas, Census stated that the different estimates are not based 
on the same criteria and therefore should not be compared. We agree 
that the surveys have different bases for identification, and we 
identify several reasons for these differences in appendix IV of the 
report. We have also noted Arkansas's and Hawaii's observations about 
the accuracy and reliability of the ACS data. 

Comments from U.S. Areas: 

Hawaii: 

The government of Hawaii generally agreed with our recommendations and 
made several related observations. In particular, in response to our 
recommendation that Interior disseminate guidelines to the affected 
jurisdictions for estimating compact impact, the government of Hawaii 
said it would be willing to consider using such guidelines if they do 
not create undue burdens. Regarding our recommendation that Interior 
work with the affected jurisdictions to evaluate current uses of 
compact impact grants and consider alternative uses, the government of 
Hawaii noted that it had always used compact impact assistance for 
direct services to compact migrants, and said it had done so 
efficiently and effectively. However, Hawaii noted that ideas to 
increase long-term capacity or efficiency, or proposals to strengthen 
support infrastructure, could be of future benefit. The government of 
Hawaii stated that a portion of the sector grants to the FAS might be 
more effectively used to provide services to their compact migrants 
and suggested that affected jurisdictions provide input on the use of 
sector grants. 

Guam: 

The government of Guam agreed in principle to the four recommendations 
in our report. Regarding the required enumerations of compact 
migrants, the government of Guam stated that Interior's decision not 
to use the enumerations to collect additional demographic data has 
resulted in the loss of valuable information. The government of Guam 
also welcomed legislative proposals for federal impact aid for 
education and restoration of Medicaid eligibility. Regarding our 
recommendation to consider uses of sector grants to address compact 
impact, the government of Guam cautioned that while such use may 
lessen impact on affected jurisdictions, diverting them from use 
within the FAS must be carefully weighed. The government of Guam also 
stated that the report does not discuss some options available in the 
amended compacts' enabling legislation to address compact impact, 
including: direct financial compensation to affected jurisdictions, 
nondiscriminatory limits on migration, and debt relief to offset 
previous costs. Our report notes the authorization of additional 
appropriations but does not address limits on migration. We added a 
note to the report to describe the debt relief provision but also note 
that it expired on February 28, 2005. 

CNMI: 

The government of the CNMI generally agreed with our findings and 
recommendations and stated that Interior should consult with the CNMI 
on developing cost guidance based on Interior Inspector General, 
Office of Management and Budget, and GAO guidance. The government of 
the CNMI also recommended that Congress provide additional 
appropriations to redress the outstanding costs for services provided 
to compact migrants from past years to the present. 

Arkansas: 

The government of Arkansas generally agreed with our findings but 
expressed serious reservations about the ACS data shown in figure 2 of 
our report. The government of Arkansas asked that figure 2 show 
Census's 2010 decennial census count based on race rather than the 
estimate of compact migrants based on ACS 2005-2009 data. We agree 
that there are differences between the counts and list some of the 
reasons for the differences in appendix IV. We have added additional 
text to the report body to present Arkansas's concerns and more 
thoroughly describe the differences between the data sources. 

Comments from Freely Associated States: 

Federated States Of Micronesia: 

The government of the FSM commented that weaknesses we identified in 
affected jurisdictions' impact cost reporting, combined with the lack 
of information on the positive contributions of compact migrants, 
leaves the net impact unknown. The FSM asked that the service of its 
citizens in the U.S. armed forces be recognized in our report. In 
response, we obtained information on the number of FAS-born persons on 
active duty in the armed forces and have included it in the report. 
Further, the FSM expressed concern that disagreements regarding the 
compact migrant enumerations will continue and requested that parties 
involved in the 2013 enumeration reach an agreement on the best 
approach. 

[Republic Of The Marshall Islands: 

The government of the Marshall Islands stated that a methodology 
should be developed to calculate net compact impact and requested that 
the contributions of Marshall Islands citizens in the U.S. armed 
forces be recognized in our report. The government of the Marshall 
Islands commented that it views the immigration privileges under the 
compact as a cornerstone of its free association with the United 
States and that any changes to them will lead to a deterioration in 
the relationship between the United States and the Marshall Islands. 
The government of the Marshall Islands also cited specific steps it 
has taken to address compact migrant impact, including establishing a 
task force working on and implementing a program to address 
communicable diseases, and producing a video for Marshallese that 
describes intending migrants' rights, duties, and responsibilities 
while living in the United States. Regarding the recommendation that 
Interior work with the U.S.-FSM and U.S.-Marshall Islands joint 
management committees to consider uses of sector grants, the 
government of the Marshall Islands stated that the amended compact 
provides only for uses of the grants in the Marshall Islands. We 
clarified some statements and our recommendation in response to this 
observation. The government of the Marshall Islands further stated 
that the amended compacts' enabling legislation authorized additional 
appropriations for grants to affected jurisdictions to offset impact 
and that it is the responsibility of Congress to compensate affected 
jurisdictions for any adverse impact. 

Republic Of Palau: 

The government of Palau generally agreed with our findings. Palau also 
emphasized that positive compact impact should be determined and asked 
that the contributions of Palau's citizens in the U.S. armed forces be 
recognized in our report. The government of Palau commented that our 
report does not adequately explore whether compact impact differs 
among FAS citizens. However, we found that not all local government 
agencies reported compact impact costs by FAS country, limiting our 
ability to perform such an analysis. Finally, the government of Palau 
stated that some persons who entered the United States after the date 
of the compacts may be lawfully present under authorities other than 
those of Section 141 of the compact and therefore would not count 
towards compact impact. We agree and have noted this in the report. 

We are sending copies of this report to the Secretary of the Interior, 
the Secretary of State, and the Director of the U.S. Census Bureau. In 
addition, this report will be available at no charge on GAO's Web site 
at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-3149 or gootnickd@gao.gov. Contact points for 
our offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Key contributors to this report are 
listed in appendix XVII. 

Signed by: 

David B. Gootnick, Director: 
International Affairs & Trade: 

List of Requesters: 

The Honorable Eni F.H. Faleomavaega:
Ranking Member:
Subcommittee on Asia and the Pacific:
Committee on Foreign Affairs:
House of Representatives: 

The Honorable Gregorio Kilili Camacho Sablan:
Ranking Member:
Subcommittee on Fisheries, Wildlife, Oceans, and Insular Affairs:
Committee on Natural Resources:
House of Representatives: 

The Honorable Daniel Akaka:
The Honorable Jeff Bingaman:
The Honorable John Boozman:
The Honorable Daniel Inouye:
United States Senate: 

The Honorable Madeleine Bordallo:
The Honorable Colleen Hanabusa:
The Honorable Mazie Hirono:
The Honorable Mike Ross:
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

This report describes migration to U.S. areas from the Federated 
States of Micronesia (FSM), the Marshall Islands, and Palau under 
those countries' compacts of free association with the United States; 
reviews approaches to enumerating these compact migrants; evaluates 
reporting of these migrant's impact on Guam, Hawaii, and the 
Commonwealth of the Northern Mariana Islands (CNMI); and reviews 
Department of the Interior (Interior) grants related to compact 
migration. In addition, appendix II provides information on the 
growing Marshallese compact migrant population in Arkansas and its 
impact. 

To describe compact migration to U.S. areas, we reviewed survey data 
from 1993 through 2010. As part of this review, to approximate the 
dispersion of compact migrants, we arranged with the U.S. Census 
Bureau (Census) to purchase a special tabulation of multiyear American 
Community Survey (ACS) data gathered from 2005 through 2009. These 
state estimates represent migrants if they are present in sufficient 
numbers to be reportable; state estimates are unreportable when fewer 
than 50 people respond in each category of cross-tabulated data. 
Census also applies statistical disclosure avoidance techniques to the 
tabulated data to protect respondent confidentiality, such as 
suppressing the number and location of compact migrants. The new 
tabulation mirrors the one used by Census to estimate the number of 
compact migrants in Hawaii in 2008 using ACS data. To determine the 
trend of migrants as a percentage of the populations of affected 
jurisdictions and identify reasons for migration, we reviewed our 
previous report on compact migrant impact[Footnote 75] and analyzed 
the information presented in previous enumerations. To estimate the 
populations of affected jurisdictions, FSM, and the Marshall Islands 
in 2003 and 2008, we used the 1999 Marshall Islands census, an 
estimate from the Marshall Islands' embassy to the U.S. for the 2011 
population, and 2000 and 2010 censuses for the FSM and the affected 
jurisdictions, assumed that the population changed at a constant rate, 
and interpolated the population counts for the years in between. 
[Footnote 76] The 1993 and 1998 estimates of affected jurisdiction 
population are existing Census estimates. 

To assess Interior and Census approaches to enumerating compact 
migrants in affected jurisdictions, we reviewed the requirement for 
the enumerations in the amended compacts' enabling 
legislation.[Footnote 77] In addition, we interviewed Census and 
Interior officials and officials in affected jurisdictions who had 
contacted or worked with Census and Interior as they developed the 
2003 and 2008 enumerations. We also reviewed affected jurisdictions' 
written critiques of the enumerations. We reviewed Office of 
Management and Budget (OMB) survey criteria,[Footnote 78] and we 
compared the surveys to these criteria by reviewing the reported 
methodology of the 2003 survey and the supporting documents for the 
2008 survey such as the enumerator's manual, Census's source and 
accuracy statement, and Census quality control review documents. We 
also conducted a literature review to identify existing studies of the 
uses and limitations of the various methods for enumerating 
populations such as compact migrants. 

To compile the compact impact costs reported by the governments of 
Guam, Hawaii, and the CNMI, we used the most recent data that they 
submitted to Interior for 1986 through 2010, Interior's 2010 compact 
impact report to Congress, and data from our previous report.[Footnote 
79] We then categorized the reported costs using the categories that 
the amended compacts' enabling legislation defines as eligible for 
compact impact funding--education, health, public safety, and social 
services and infrastructure related to such services--to identify the 
main sources of compact impact reported by the affected jurisdictions. 
For additional context, we reviewed the narrative of the reports 
submitted by affected jurisdictions and interviewed compact migrants 
and officials in affected jurisdictions. To identify the eligibility 
of compact migrants for selected federal programs that may help 
address the compact impact on affected jurisdictions, we reviewed 
existing legislation and discussed our findings with officials from 
affected jurisdictions and subject matter experts. 

To evaluate the affected jurisdictions' estimates of compact impact 
costs, we compared the costs that the affected jurisdictions had 
reported to Interior since 2004 with cost estimation criteria that we 
developed based on OMB guidelines[Footnote 80] as well as our own 
guidance on cost -benefit analyses,[Footnote 81] a previous report on 
costs associated with illegal alien schoolchildren,[Footnote 82] and 
requirements in the amended compacts' enabling legislation. We 
identified the methodologies used by local government agencies in the 
affected jurisdictions to develop their compact impact costs and 
determined their limitations by reviewing the compact impact reports; 
interviewing officials from many of the reporting agencies in affected 
jurisdictions; and collecting information from the Guam and the CNMI's 
single audit reports. Using our cost criteria, we developed questions 
and circulated them to affected jurisdictions' reporting agencies, 
providing them an opportunity to further explain how they derived 
their estimates. Not all agencies responded to these questions; 
therefore, additional examples beyond the ones we have identified may 
exist. Table 8 includes Hawaii's most recent reported compact impact 
costs which were submitted to Interior in August 2011. However, our 
analysis of compact impact reporting does not include this 
information. Officials from Hawaii's Department of Human Services, 
Department of Health, and Department of Education said that their 
reporting methodologies had generally not changed since their last 
report, which was submitted in 2008 and which we included in our 
analysis. However, the Department of Education said that it excluded 
federal funds from its 2008 through 2011 compact impact costs and 
corrected its reporting error regarding the number of compact students 
for 2006 through 2008. In addition, the Department of Health said that 
the Tuberculosis Branch changed its methodology and the Family Health 
Services Division changed its presentation of the data to show 
excluded federal funds. To identify federal funding received by Guam 
and the CNMI for programs serving compact migrants, we analyzed single 
audit reports from 2005 through 2009 in the CNMI and from 2004 through 
2008 in Guam. 

To assess Interior's guidelines on compact impact reporting, we 
reviewed the requirements contained in the amended compacts' enabling 
legislation, and we identified and reviewed Interior's 1994 compact 
impact reporting guidelines and the Interior Office of Inspector 
General's 1993 report that prompted the creation of these guidelines. 
We also interviewed officials from the affected jurisdictions and 
Interior regarding their use of these guidelines to develop cost 
estimates. To assess Interior's compliance with the congressional 
reporting requirements of the amended compacts' enabling legislation, 
we reviewed the legislation, met with Interior officials, and assessed 
the Interior's 2010 report to Congress against the specific elements 
required in the legislation. 

To describe compact migrants' participation in local economies, we 
generally used data from the Micronesian surveys in 1997 and 2003 as 
reported in the 2008 report of the 2003 survey,[Footnote 83] 
supplementing these data where possible with additional information 
from local and national agencies and other literature. To determine 
whether additional data on the compact migrants' role in the economy 
exist, we contacted agencies from affected jurisdictions that address 
labor and taxation and reviewed reports and data sets. These sources 
of additional information and data include the following: 

* To describe compact migrant health status and the health and 
education systems in the FAS, we reviewed and summarized published 
literature. 

* To describe compact migrants' contributions to the labor market in 
the CNMI, we analyzed data from the CNMI Department of Finance for 
2001 through 2009, comparing the size of the compact migrant labor 
force to the size of the overall CNMI labor force and the income of 
the compact migrants to that of the general population. 

* To compare the amount of taxes paid by compact migrants with the 
amount paid by the general population in Guam, we used data from the 
2008 and 2009 Guam Annual Census of Establishments, the 2008 and 2009 
Guam Current Employment Reports, the 2008 Guam Statistical Yearbook, 
and the 2008 migrant survey. These data allowed us to estimate under 
certain assumptions[Footnote 84] the number of compact migrants and 
others working in the private and public sectors,[Footnote 85] their 
average wages, and taxes paid. The method we used to prepare this 
estimate drew on a method first outlined by an official in the Guam 
Bureau of Statistics and Plans. 

* To estimate the amount of remittances that migrants sent and 
received while in the U.S. areas, we analyzed data from the Inter-
American Dialogue, the fiscal year 2008 Economic Reviews of the FSM 
and the Marshall Islands, and data reported in the 2008 report of the 
2003 survey. Because of the limitations and significant variation in 
the estimates provided by these three sources, we determined that 
these data were not sufficiently reliable for our purposes. 

* To determine the number of FAS-born persons serving in the U.S. 
armed forces, we requested a special tabulation from the Department of 
Defense's Active Duty Personnel Master and Reserve Components Common 
Personnel Data System. 

To review Interior's compact impact grants, we reviewed our previous 
report on Interior grant management,[Footnote 86] the requirements of 
the amended compacts' enabling legislation, and Interior's 2010 
Financial Assistance Manual. We assessed the management of the grants 
against the legislation and manual by reviewing Interior's compact 
impact grant files for Guam, Hawaii, and the CNMI for fiscal years 
2004 through 2011. In each grant file, we reviewed grant narratives 
and correspondence and collected the grant name, number, amount, 
description, status, remaining balance, and purpose, as well as any 
funding redirections or deobligations. To determine the extent to 
which compact sector grants may address compact impact, we interviewed 
compact migrants and Interior and affected jurisdiction officials and 
collected grant allocation data from Interior for compact sector 
grants. We then discussed the nature of sector grants and compact 
impacts in the affected jurisdictions with Interior officials to 
identify the amount and purpose of compact sector grants that could be 
linked to addressing compact migrant impact. 

To provide information on the migrant population and impact in 
Arkansas, we met with state and Springdale, Arkansas officials and 
with employers and migrants. We reviewed existing Census population 
reports and the Census tabulation of ACS data as well as existing 
Arkansas government reporting and published literature on Arkansas's 
compact migrant impact. Although the amended compacts' enabling 
legislation does not define Arkansas as an affected jurisdiction and 
the state government therefore does not submit reports to Interior, we 
compiled data available for 2004 through 2010 from the Arkansas 
Department of Health, Arkansas Department of Correction, and the 
Springdale School District. We then assessed the limitations of these 
data in the same manner as we assessed the data for affected 
jurisdictions. 

We conducted this performance audit from September 2010 through 
October 2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Growth and Impact of Marshallese Compact Migration in 
Arkansas: 

In response to congressional interest, this case study reviews 
existing enumerations of the compact migrant population of Arkansas 
and their impact. Arkansas's compact migrant population is almost 
exclusively from the Marshall Islands and is concentrated in the 
rapidly growing northwest Arkansas counties of Benton and Washington 
(see figure 7).[Footnote 87] The amended compacts' enabling 
legislation does not define Arkansas as an affected jurisdiction; 
therefore, the state is not eligible to receive compact impact grants, 
and data on Arkansas's migrant population and impact are limited in 
comparison to data for the affected jurisdictions. 

Figure 7: Northwest Arkansas: 

[Refer to PDF for image: map of Arkansas] 

Depicted on the map: 

Benton County; 
Washington County; 
City of Springdale; 
Little Rock. 

Source: Map Resources. 

[End of figure] 

Census Data Provide Varying Estimates of Compact Migrants in Arkansas: 

Tabulations of data from the 2005-2009 ACS show an estimated 1,150 
(with a 90 percent confidence interval of 933 to 1,367) Marshallese 
compact migrants living in Arkansas.[Footnote 88] The 2010 decennial 
census reports that 4,324 persons in Arkansas responding to the race 
question on the 2010 form identified themselves as 
Marshallese.[Footnote 89] Additionally, in 2009 and 2010, the 
Springdale School District reported that 1,323 and 1,579 students, 
respectively, identified as Pacific Islanders when enrolling in 
Springdale schools. In comments on a draft of this report, the 
government of Arkansas stated that it had serious doubts about the 
count of Arkansas migrants using ACS data and Census commented that 
the estimates described here are not based on the same criteria and 
should not be compared. See appendix IV of this report for a further 
discussion of the differences between ACS and 2010 decennial census 
data. 

Local Response to Marshallese Migration: 

Concerns in Arkansas regarding compact migrants are similar to those 
expressed by officials in affected jurisdictions. Arkansas government 
officials and service providers cited the following concerns: migrant 
students lagging academically behind their peers; low levels of family 
involvement in education; the prevalence of communicable and 
noncommunicable diseases; reluctance of migrants to use preventive 
health care; language barriers; cultural barriers; and crowded living 
conditions. 

To address some of these concerns, Northwest Arkansas local government 
and social service agencies have begun to offer services to the 
Marshallese community in recent years. For example: 

* The Springdale School District has provided supplemental tutoring 
and employs two Marshallese translators. 

* The Jones Center for Families, a nonprofit community service 
organization, employs a Marshallese Community Outreach Coordinator and 
has helped facilitate the activities of the Gaps in Services to 
Marshallese Task Force, a network of interested individuals headed by 
a retired Jones Center employee. 

* The task force has used grants from the Centers for Disease Control 
and Prevention and the Arkansas Minority Health Commission to survey 
the health concerns of Marshallese and prepare an outreach booklet and 
DVD to aid Marshallese migrants in adapting to life in the state. 
[Footnote 90] 

* The Washington County Department of Health dedicates four staff to 
its Marshallese Outreach Team and will add two more staff when it 
opens the Marshallese outreach clinic in 2011. 

* Some local agencies noted that they work in cooperation with the 
Marshall Islands consulate in Springdale. Opened in 2008, this 
consulate is the only FAS consulate in the continental United States. 

Arkansas's Growing Costs of Serving Compact Migrants Are Primarily 
Documented for Education and Health: 

Data provided by Arkansas state officials for 2004 through 2010 
identified approximately $51 million in costs for education, health, 
and public safety services to compact migrants (see table 4). 
Available data from Arkansas are not comparable with data from 
affected jurisdictions. Arkansas does not collect data on a number of 
costs reported by Guam, Hawaii, and the CNMI, particularly costs for 
social services. In addition, not all Arkansas state agencies compiled 
their cost data on compact impact annually, whereas the affected 
jurisdictions have generally compiled their data annually. 

Table 4: Estimated Costs for Services to Arkansas Compact Migrants, 
2004-2010: 

Dollars in thousands and rounded to nearest thousand: 

Education[A]; 
2004: $4,058; 
2005: $5,473; 
2006: $6,411; 
2007: $7,047; 
2008: $8,135; 
2009: $8,469; 
2010: $10,129; 
Total: $49,721. 

Health[B]; 
2004: $163; 
2005: $172; 
2006: $137; 
2007: $198; 
2008: $182; 
2009: $169; 
2010: $254; 
Total: $1,276. 

Public safety[C]; 
2004: Not reported; 
2005: Not reported; 
2006: Not reported; 
2007: $9; 
2008: $54; 
2009: $54; 
2010: $116; 
Total: $233. 

Total; 
2004: $4,222; 
2005: $5,645; 
2006: $6,547; 
2007: $7,253; 
2008: $8,372; 
2009: $8,692; 
2010: $10,499; 
Total: $51,231. 

Source: GAO analysis of Arkansas data. 

Note: Service costs may not sum to totals because of rounding. 

[A] Based on per pupil expenditures in Springdale, Arkansas. Federal 
funds are included in the reported expenditures for 2004 and 2005 but 
excluded for 2006 through 2010. 

[B] Arkansas estimated state costs based upon a Department of Health 
funding of 70 percent Federal and 30 percent State, except for 
tuberculosis and sexually transmitted diseases, which were funded at 
50 percent Federal and 50 percent State. In 2008, the Arkansas 
Department of Health reported that costs for providing health services 
to Marshallese in Arkansas were roughly $2.2 million in fiscal year 
2007; this estimate did not include administrative costs and did not 
deduct federal funds or revenue received. In 2011, the Department of 
Health updated its 2007 estimate by subtracting revenues and federal 
funds, reducing the estimated costs to just under $200,000. 

[C] Based on average expenditure per day per Marshallese inmate 
reported by the Arkansas Department of Correction and Arkansas 
Department of Community Correction. It is unclear if Federal funds are 
included. 

[End of table] 

Limitations in Arkansas Cost Data: 

Education. The estimated education service costs are for the 
Springdale School District, where most Marshallese school children 
live. The estimate for Springdale is based on average per-pupil 
expenditures, similar to some of the affected jurisdictions' cost 
estimates. However, these expenditures may overstate actual costs to 
the extent there is excess capacity in the schools to absorb a 
marginal increase in population. The estimates may also understate 
actual costs by not including higher than average costs for additional 
services to Marshallese, such as language education. Finally, student 
population data prior to 2009 are incomplete.[Footnote 91] 

Health. Arkansas estimated costs for health services to compact 
migrants by compiling costs for the population identified as of 
Pacific Islander ethnicity; as a result, Arkansas's estimates may 
overstate compact migrant health costs by including services to 
Pacific Islanders who are not compact migrants. However, the estimates 
do not include costs for the Arkansas Women, Infants and Children 
Program and were not complete for all years for tuberculosis and 
sexually transmitted disease treatment, potentially leading to an 
underestimate of total costs. 

Social services. Arkansas does not track the use of some state-funded 
services by ethnicity and therefore could not estimate the costs of 
providing these services to compact migrants.[Footnote 92] However, 
officials stated that compact migrants are eligible for programs such 
as the state's Division of Developmental Disabilities Services; 
Division of Youth Services; and ARKids First, which provides health 
insurance to low-income U.S.-citizen children of compact migrants. 
Unlike affected jurisdictions, Arkansas does not provide Medicaid 
equivalent services to noncitizen compact migrants. 

Arkansas Migrants Affect the Local Economy, but Data on Their Impact 
Are Limited: 

As in affected jurisdictions, Arkansas compact migrants contribute to 
the local economy through payment of taxes and participation in the 
labor market. 

Taxes. Marshallese are subject to federal, state, and local taxes; 
however Arkansas does not disaggregate the tax revenue by ethnic 
categories or citizenship and there are no data on consumption and 
remittances. 

Labor market. Marshallese fill a significant niche in the local 
poultry industry. According to employers in northwest Arkansas, 
Marshallese represent between 14 and 37.9 percent of the total 
workforce at some plants of major poultry producers, such as Tyson, 
Cargill, and George's. Tyson officials in Springdale stated that they 
have begun referring some Marshallese job applicants to plants 
elsewhere in Arkansas and in Oklahoma. In addition, Tyson may begin 
recruiting workers in the Marshall Islands. According to Marshall 
Islands officials, Tyson representatives have visited the Marshall 
Islands. 

[End of section] 

Appendix III: American Community Survey Estimates of Compact Migrants: 

ACS Estimates of Compact Migrant Populations in U.S. Areas: 

Table 5 shows the estimated population of the compact migrants from 
each FAS in the U.S. states based on tabulations of Census' 2005-2009 
ACS. Taking into account sampling uncertainty, the table shows the 
lower-bound and upper-bound population interval that corresponds to a 
90 percent confidence interval. Estimates of compact migrants from 
each FAS in Guam and the CNMI, using data from Census's 2008 survey of 
compact migrants, are shown for comparison. 

Table 5: Compact Migrant Populations by U.S. Area of Residence and FAS 
of Origin: 

U.S. area of residence: Guam[A]; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 549; 
FSM: 16,358; 
Palau: 1,399; 
Total population: 18,305 (14,866-21,744). 

U.S. area of residence: Hawaii[B]; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 3,535 (2,502-4,568); 
FSM: 8,320 (7,028-9,612); 
Palau: 205 (86-324); 
Total population: 12,060 (10,579-13,541). 

U.S. area of residence: California; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 1,565 (822-2.308); 
FSM: 630 (364-896); 
Palau: 720 (381-1,059); 
Total population: 2,920 (2,124-3,716). 

U.S. area of residence: Washington; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 1,830 (1,397-2,263); 
FSM: 795 (448-1,142); 
Palau: 175 (73-277); 
Total population: 2,800 (2,225-3,375). 

U.S. area of residence: Oregon; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 515 (277-753); 
FSM: 1,510 (1,044-1,976); 
Palau: 185 (53-317); 
Total population: 2,210 (1,713-2,707). 

U.S. area of residence: CNMI[A]; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 100; 
FSM: 1,560; 
Palau: 360; 
Total population: 2,100[C[(1,589-2,611)] 11). 

U.S. area of residence: Utah; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 480 (175-785); 
FSM: Not reported by Census[D]; 
Palau: Not reported by Census[D]; 
Total population: 1,630 (766-2,494). 

U.S. area of residence: Oklahoma; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 545 (303-787); 
FSM: 555 (256-854); 
Palau: Not reportable[E]; 
Total population: 1,190 (778-1,602). 

U.S. area of residence: Florida; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 295 (98-492); 
FSM: Not reported by Census[D]; 
Palau: Not reported by Census[D]; 
Total population: 1,170 (780-1,560). 

U.S. area of residence: Arkansas; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 1,150 (933-1,367); 
FSM: Not reportable[E]; 
Palau: Not reportable[E]; 
Total population: 1,155 (938-1,372). 

U.S. area of residence: Missouri; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: Not reportable[E]; 
FSM: 970 (733-1,207); 
Palau: Not reportable[E]; 
Total population: 1,090 (824-1,356). 

U.S. area of residence: Arizona; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 680 (342-1,018); 
FSM: 265 (61-469); 
Palau: Not reportable[E]; 
Total population: 1,030 (652-1,408). 

U.S. area of residence: Remaining states; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 1,590 (1,099-2,081); 
FSM: 5,465 (4,467-6,463); 
Palau: 1,625 (1,098-2,152); 
Total population: 8,680 (7,517-9,843). 

U.S. area of residence: Total; 
Population by FAS of origin (low and high estimate): 
Marshall Islands: 12,944 (11,639-14,249); 
FSM: 38,168 (35,811-40,525); 
Palau: 5,154 (4,426-5,882); 
Total population: 56,345 (49,642-63,048). 

Source: GAO analysis of a special Census tabulation of American 
Community Survey 2005-2009 data for U.S. states; Census 2008 compact 
migrant survey data for Guam and the CNMI. 

Notes: Numbers may not add due to rounding. 

[A] For Guam and the CNMI, Census data did not include a margin of 
error for the population broken out by FAS. 

[B] Estimate of compact migrants in Hawaii is based on 2005-2009 ACS 
data. The 2008 enumeration for Hawaii that used 2005-2007 ACS data 
estimated compact migrants within a 90 percent confidence interval at 
9,479 to 14,951. 

[C] According to Census, Census tabulated CNMI total by FAS using 
Saipan survey data. Census estimated an additional 80 compact migrants 
on the other islands of the CNMI but did not tabulate them by FAS. 

[D] Census suppressed some locations and numbers of migrants for 
privacy reasons. Suppression is a method of disclosure avoidance used 
to protect individuals' confidentiality by not showing (suppressing) 
the cell values in tables of aggregate data for cases where only a few 
individuals or businesses are represented or dominate the cell value. 
The cells that are not shown are called primary suppressions. To 
ensure the primary suppressions cannot be closely estimated by 
subtracting the other cells in the table from the marginal totals, 
additional cells are also suppressed. These additional suppressed 
cells are called complementary or secondary suppressions. Values for 
cells that are not suppressed remain unchanged. 

[E] The 90 percent margin of error exceeded the value of the estimate 
and we view these as unreportable. 

[End of table] 

[End of section] 

Appendix IV: 2010 Decennial Census Data on Micronesians by Race: 

The 2010 decennial census identified 22,434 Native Hawaiian or Pacific 
Islanders--alone or in combination with another race--who identified 
themselves specifically as Marshallese residing in the 50 U.S. states 
in 2010.[Footnote 93] The largest Marshallese populations were in 
Hawaii, Arkansas, and Washington, which together accounted for 62 
percent of the total reported Marshallese residing in the 50 states. 
See table 6. As of September 2011, Census has not released a separate 
count of U.S. residents who identified themselves as one of the FSM 
ethnicities or Palauan, but plans to do so between December 2011 and 
April 2012.[Footnote 94] As of November 2011, Census race data for 
Guam and the CNMI had yet to be released. 

Table 6: 2010 Census Counts of Marshallese by State[A]: 

State: Hawaii; 
Number: 7,412. 

State: Arkansas; 
Number: 4,324. 

State: Washington; 
Number: 2,207. 

State: California; 
Number: 1,761. 

State: Oklahoma; 
Number: 1,028. 

State: Oregon; 
Number: 970. 

State: Utah; 
Number: 793. 

State: Arizona; 
Number: 666. 

State: Texas; 
Number: 550. 

State: Other states[B]; 
Number: 2,723. 

State: Total[C]; 
Number: 22,434. 

Source: GAO analysis of U.S. Census tabulations of 2010 census. 

[A] The census counts comprise respondents who identified themselves 
as Marshallese alone or in combination with another race. 

[End of table] 

The number of Marshallese reported by the 2010 decennial census 
differs from estimates of Marshallese compact migrants derived from 
the Census 2005-2009 ACS. For example, the 2010 census reported 7,412 
Marshallese in Hawaii and 4,324 in Arkansas, while the ACS tabulation 
estimates 3,535 and 1,150 Marshallese compact migrants in Hawaii and 
Arkansas, respectively. The census counts are not meant to be compared 
with ACS 5 year estimates of compact migrants and several factors may 
explain the differences: 

* The ACS and 2010 census figures use different definitions. The ACS 
compact migrant estimates include only those born in the Marshall 
Islands who arrived in the United States under the terms of the 
compact after 1986 and their children. The census counts are defined 
by the respondents' reported race and not limited by the post-1986 
time frame of the compact. 

* The ACS and 2010 census figures have different time frames. The ACS 
estimates are based on data collected from 2005-2009 and do not 
include compact migrants to U.S. areas in 2010.[Footnote 95] In 
addition, the ACS estimate does not include births that are included 
in the 2010 counts. 

* The ACS and 2010 census use different approaches. The 2010 census 
attempts to reach all persons in the United States, while the ACS is a 
sample of the population. The sampling method used by the ACS was not 
specifically designed to make estimates of a population as small as 
the compact migrants. 

* The ACS and 2010 census have different levels of outreach. Census 
ran extensive public service announcements of the 2010 survey, and 
local governments and community groups encouraged participation. 
However, Census does not conduct a similar public campaign to 
encourage participation in the ACS. 

[End of section] 

Appendix V: Attributes of 2003 and 2008 Approaches to Enumerating 
Compact Migrants: 

Table 7 shows key attributes, related to survey design, coverage, 
nonresponse, measurement, and sampling error, for the 2003 and 2008 
Census approaches to enumerating compact migrants. 

Table 7: Attributes of 2003 and 2008 Census Approaches to Compact 
Migrant Enumerations: 

Survey design; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Census-trained 
enumerators from each FAS interviewed all known compact migrants from 
their own countries and asked these interviewees to refer them to 
other migrants from their home country, until all known compact 
migrants had been contacted; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: The ACS is a large block sample probability survey conducted 
on a continuing basis in the 50 states and the District of Columbia. 
The ACS uses a differential sampling rate design that allows smaller 
areas to be sampled at a higher rate. Current residents are 
interviewed--that is, anyone in the house on the day of the interview 
who has been staying there for more than 2 months, regardless of 
his/her usual residence; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: The two COFA surveys use a block sample probability survey 
of housing units in Guam and the island of Saipan in the CNMI. FAS 
native speakers were available to assist if needed with the survey.; 
Census selected the 2008 migrant survey blocks using probabilities 
based on the block's concentration of migrants as of the 2000 
decennial census and local input on changes in migrant location since 
2000. Census estimated the compact migrant population of the CNMI's 
other islands using the 2000 Census. Approximately 10 percent of the 
CNMI population lives on the other islands and few compact migrants 
live there. 

Coverage: 

Coverage rate; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: The coverage rate 
in the snowball method used to count compact migrants in 2003 was not 
assessed and can not be determined. Owing to a shortage of funds, the 
2003 enumeration did not administer the full survey or use the same 
methods to enumerate compact migrants on Hawaiian islands other than 
Oahu; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: The estimated coverage rate for the total population in Hawaii 
in 2007 is 92.9 percent. The ACS does not estimate the coverage rate 
for respondents by foreign-born status or by place of birth; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: The survey covers the population residing in housing units 
or group quarters. The COFA survey does not report a coverage rate. 

Reaching target Population; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: The snowball 
survey was designed to identify migrants and collect data on migrants. 
In general, the snowball method can reach rare populations with strong 
networks who are geographically concentrated. However, the 2003 survey 
almost certainly undercounts the compact migrant population by 
excluding those not linked to the compact migrant network. The 
snowball method could reach a homeless person if they were connected 
to the migrant community and can be contacted, but homeless persons 
may be less connected and therefore less likely to be counted; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: The ACS was not specifically designed to make estimates of a 
population as small as the compact migrants. Other sampling techniques 
are needed to make reliable estimates of a population this small.[A] 
Only surveys homeless in group quarters, i.e. living in shelters; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: Census designed the 2008 COFA survey to estimate the compact 
migrant population but interviewed a number of non-migrants within the 
sample blocks. Included a number of non-traditional dwellings in its 
survey, including living quarters open to the elements, but may not 
have captured homeless living outside of structures on these tropical 
islands. 

Nonresponse: 

Proxy response; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Not documented; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: ACS accepts proxy responses from relatives or other members of 
the household; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: The COFA Survey accepted proxy responses from neighbors. 

Nonresponse; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Nonresponse was 
not documented. It is not possible to calculate a nonresponse rate for 
the snowball method used in the 2003 survey; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: Census uses three modes-mail, phone, and in-person-and 
acceptance of proxy response to attempt to ensure a high response 
rate. ACS estimates include a nonresponse bias analysis; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: Census took steps to achieve high response rates, including 
up to 3 personal interviews and leaving a Notice of Visit with the 
interviewer's phone number in situations of noncontact. 

Nonresponse Rate; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Not applicable; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: The response rate is more than 97 percent among households for 
the ACS in Hawaii. This nonresponse rate is acceptable by OMB 
Standards. The response rate among compact migrants is not known. 
Bias may exist due to nonresponse on items used to identify compact 
migrants[B]; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: The weighted response rate was 89 percent in Guam and 100 
percent in CNMI, which is acceptable by OMB standards. However, Census 
did not provide an unweighted response rate. Proxy respondents were 
used; however, the non-proxy and substitution response rate was not 
included in the report of the overall response rate, indicating that 
the response rate is overstated. 

Nonresponse bias; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Not documented[C]; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: Nonresponse bias was found in the ACS by mode and language 
spoken at home[D]; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: Census did not provide documentation on the potential effect 
of proxy respondents in the response rate or of a nonresponse bias 
analysis. 

Measurement: 

Collection strategy & content; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: In person 
interview[E];
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: The ACS is collected in three modes: mailout-mailback, 
telephone, and personal interview. The ACS mail form asks the 
citizenship question differently than the personal interview or 
telephone questionnaire. Year of entry and place of birth are 
consistent across mode; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: The 2008 COFA survey involved personal interview, with 
interviewer telephone information left at the housing quarters in 
situations of noncontact. 

Cultural factors; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Pairing 
respondents with culturally similar interviewers may increase 
response, but fears of deportation from the affected jurisdiction or 
eviction from housing may have inhibited some migrants from 
participating in the survey or from fully disclosing their personal 
information; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: Compact migrants may have been disproportionately likely not 
to respond across modes. Fears of deportation from the affected 
jurisdiction or eviction from housing may have inhibited some migrants 
from participating in the survey or from fully disclosing their 
personal information; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: The 2008 COFA survey used a form that is similar to the 2000 
Census form but did not carry out additional testing to identify 
potential cultural factors such as racial tensions when it was used to 
survey compact migrants. Fears of deportation from the affected 
jurisdiction or eviction from housing may have inhibited some migrants 
from participating in the survey or from fully disclosing their 
personal information. 

Sampling error: 

Sampling frame; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Not applicable; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: The sampling frame for the ACS is the Master Address File. The 
Master Address File is updated, but certain housing types are 
disproportionately missed[F]; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: Census used the 2000 Census frame to select geographic 
locations that Census then canvassed and re-listed for a more up-to-
date list of housing units. 

Sample size; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Not applicable; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: Approximately 58,515 people in housing units and 1,055 people 
in group quarters were interviewed in Hawaii; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: 4,945 units in Guam and 2,193 in Saipan. Census did not 
document the extent of their use of supplemental sampling. 

Estimates; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Produces point-in-
time counts. The snowball method is designed to enumerate the compact 
migrant population. The enumeration is likely an undercount; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: Produces multi-year estimates that are not equivalent to point-
in-time estimates. Multi-year trends are not comparable over time. The 
ACS is designed to detect changes in patterns rather than to make 
counts.[G] The result from the survey is an estimate and not an 
enumeration. May be biased due to nonresponse and coverage error; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: Produces point-in-time estimates of the compact migrant 
population. Results from the survey are estimates and not 
enumerations. The estimates are comparable between Guam and Saipan.; 
May be biased due to proxy responses. 

Variance estimation method; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Not applicable; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: The ACS estimated variance using the successive differences 
replication method. This approach will generally produce an accurate 
estimate of the standard error without consideration of the type of 
statistic or the complexity of the sample design; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: Variance estimates did not clearly account for the final 
analysis weights (including nonresponse adjustments and supplemental 
sample adjustments) and estimation process, such as by using replicate 
weights, and will therefore likely result in an underestimate of the 
variance. For Saipan in the CNMI, supplemental samples selected after 
the original sample involve conditional probabilities, and result in 
unequal weighting. 

Variance size; 
2003: Snowball survey of Guam, Hawaii, and the CNMI: Not applicable; 
2008: Tabulation of American Community Survey (ACS) 2005-2007 data for 
Hawaii: Relative error is 22 percent. Census does not provide a 
standard of required precision; 
2008: Compact of Free Association (COFA) Migrant Survey of: Guam and 
the CNMI: Relative error is 19 percent in Guam and 24 percent in 
Saipan. Census does not provide a standard of required precision. 

Source: GAO summary of documentation from, and interviews with, Census 
and Interior. 

[A] G. Kalton, "Methods for Oversampling Rare Subpopulations in Social 
Surveys," Survey Methodology, vol. 35. no. 2 (2009): 125-141; C. 
Alexander and A. Navarro, "The Quality of Estimates from the American 
Community Survey for Small Population Groups," Proceedings of the 2003 
Joint Statistical Meetings (2003). 

[B] Nonresponse bias was assessed in the 2004 ACS on the three key 
items used to identify compact migrants: citizenship status, year of 
entry, and place of birth. The allocation rate for citizenship was low 
at 0.3 percent, similar to allocation rate for the 2004 Current 
Population Survey Annual Social and Economic Supplement. The rates for 
year of entry and place of birth were moderate at 7.3 percent and 5.5 
percent, respectively. In the 3-year period of data used to produce 
the estimates, the allocation rates for place of birth ranged from 4.8 
to more than 6 percent. Year of entry was allocated in up to 11 
percent of the cases. J. Menendez, "Comparison of ACS and ASEC Data on 
Citizenship, Year of Entry and Region of Birth: 2004," U.S. Census 
Bureau (2007), available at [hyperlink, 
http://www.census.gov/acs/www/Downloads/library/2007/2007_Menendez_01.pd
f]. 

[C] Census asserted in comments on a draft of this report that the 
2003 survey effort faced similar nonresponse bias issues as 
highlighted for the 2008 COFA surveys. 

[D] In general, allocation rates were similar between linguistically 
isolated households and English-only speaking households across all 
three modes of data collection. Households that were not 
linguistically isolated but contained people who spoke languages in 
addition to English had higher allocation rates across all three 
modes. Pamela McGovern, A Quality Assessment of Data Collected in the 
American Community Survey for Households with Low English Proficiency, 
(Washington, DC: U.S. Census Bureau, 2004). 

[E] Census asserted in comments on a draft of this report that the 
2003 effort was similar in this regard to the 2008 COFA surveys, with 
interviewer telephone information left at the housing quarters in 
situations of noncontact. 

[F] Clifford L. Loudermilk and Mei Li, "A National Evaluation of 
Coverage for a Sampling Frame Based on the Master Address File (MAF)," 
Proceedings of the Joint Statistical Meetings (2009); Heather 
MacDonald, "The American Community Survey: Warmer (More Current) but 
Fuzzier (Less Precise) than the Decennial Census," Journal of the 
American Planning Association, vol. 72, no. 4 (2006); Xijian Liu, 
"Impact of MAF-Based Frame Coverage on Survey Estimates," Proceedings 
of the Joint Statistical Meetings (2009). 

[G] Alexander and Navarro (2003) show that when the population is 
changing rapidly over the period, the estimate from multiyear data 
lags behind the actual value using the 5-year data. The large margin 
of error around the 3-year estimates makes it more likely that the 
upper-bound of the confidence interval meets or exceeds the actual 
population value for a rapidly changing small population. 

[End of table] 

[End of section] 

Appendix VI: Compact Impacts Reported by Affected Jurisdictions: 

Since 1986, affected jurisdictions have submitted to Interior compact 
impact reports that include descriptions of, and estimated costs for, 
education, health, public safety, and social services that local 
government agencies provided to compact migrants (see table 8 for 
costs reported for 1986 through 2010). However, assessed against best 
practices for cost estimation, the 2004-2010 estimates contain a 
number of limitations with regard to accuracy, adequate documentation, 
and comprehensiveness, affecting the reported costs' credibility and 
preventing a precise calculation of total compact impact on the 
affected jurisdictions. 

Table 8: Affected Jurisdiction Compact Impact Estimates, 1986-2010: 

Dollars in millions: 

Year: 1986-95; 
Guam: $60.6; 
Hawaii: $23.4[A]; 
CNMI: $43.7 - $71.7[B]; 
Total: $127.7 - $155.7. 

Year: 1996; 
Guam: $16.1; 
Hawaii: $6.4; 
CNMI: $11[C]; 
Total: $33.5. 

Year: 1997; 
Guam: $19.1[D]; 
Hawaii: $12.2; 
CNMI: $13.7; 
Total: $45. 

Year: 1998; 
Guam: $19.1; 
Hawaii: $12.4; 
CNMI: $15.1; 
Total: $46.6. 

Year: 1999; 
Guam: $18.9; 
Hawaii: $14.1; 
CNMI: $12.3; 
Total: $45.3. 

Year: 2000; 
Guam: $24.5; 
Hawaii: $17.5; 
CNMI: $9.2; 
Total: $51.2. 

Year: 2001; 
Guam: $23.4; 
Hawaii: $21.5; 
CNMI: $4.6; 
Total: $49.5. 

Year: 2002; 
Guam: $23.3; 
Hawaii: $30.4; 
CNMI: $4.6; 
Total: $58.4. 

Year: 2003; 
Guam: $30.9; 
Hawaii: $47.4; 
CNMI: $4.2; 
Total: $82.5. 

Year: 2004; 
Guam: $31.2; 
Hawaii: $55.3; 
CNMI: $10; 
Total: $96.5. 

Year: 2005; 
Guam: $28.2; 
Hawaii: $66.9; 
CNMI: $10.3; 
Total: $105.4. 

Year: 2006; 
Guam: $42.2; 
Hawaii: $81; 
CNMI: $9.7; 
Total: $132.9. 

Year: 2007; 
Guam: $47.3; 
Hawaii: $90.8; 
CNMI: $8.6; 
Total: $146.7. 

Year: 2008; 
Guam: $53.3; 
Hawaii: $101; 
CNMI: $8.2; 
Total: $162.5. 

Year: 2009; 
Guam: $58.7; 
Hawaii: $118.8; 
CNMI: $4; 
Total: $181.5. 

Year: 2010; 
Guam: $65.7; 
Hawaii: $114.9; 
CNMI: $4.7; 
Total: $185.3. 

Year: Total; 
Guam: $562.5; 
Hawaii: $814.1; 
CNMI: $173.9 - $201.9; 
Total: $1,550 - $1,579. 

Source: GAO analysis of compact impact reporting and grant proposals. 

Notes: Not all local government agencies in affected jurisdictions 
reported compact impact every year, although costs may have been 
incurred. 

Amounts shown are rounded and unadjusted for inflation. 

Amounts shown for the CNMI and Hawaii for 1986 through 2000 are from 
GAO-02-40. Amounts shown for Guam for 1986 through 2003 are from its 
2003 compact impact report; for 2004 through 2010, from its 2010 
report. Amounts shown for Hawaii for 2001 through 2003 are from its 
2002 to 2004 compact impact reports; amounts for 2004 through 2007 are 
from its 2007, 2008, and 2011 reports; amounts for 2008 through 2010 
are from its 2011 report. Amounts shown for the CNMI for 2001 through 
2003 are from its 2004 compact impact grant proposal, and amounts for 
2004 through 2010 are from its 2008-2010 annual compact impact grant 
proposals. Guam and the CNMI calculated costs on a fiscal year basis; 
Hawaii's costs are a combination of fiscal year and calendar year 
costs. 

[A] Hawaii reported education and inmate incarceration costs for 
compact migrants for 1988 through 1995 in compact impact reports. 

[B] The CNMI's range of estimated costs for 1986 through 1995 was 
provided in a 2000 CNMI congressional testimony. 

[C] The CNMI's costs for 1996 were calculated for the government by 
the Hay Group/Economic Systems, Inc. 

[D] Guam's costs for 1997 were calculated for the government by Ernst 
& Young, LLP. Guam's estimates for 1996, 1998, and 1999 were derived 
from the 1997 Ernst & Young calculations, although costs associated 
with the hospital that receives government funding were added 
beginning in 1998. 

[End of table] 

Cost Estimation Best Practices Call for Accuracy, Adequate 
Documentation, and Comprehensiveness: 

Best practices and guidance state, among other things, that to be 
credible, cost estimations should be characterized by accuracy, 
adequate documentation, and comprehensiveness.[Footnote 96] 

* Accuracy. Estimates should contain few errors and reflect actual 
costs. 

* Adequate documentation. Cost estimates should include a detailed 
description of the derivation of the reported costs, such as the 
source data used, the calculations performed and their results, and 
the methodology used. Cost estimates should be captured in such a way 
that the data can be traced back to, and verified against, their 
sources, so that estimates can be replicated and updated. 

* Comprehensiveness. Estimates should be structured in sufficient 
detail to ensure that cost elements are neither omitted nor double 
counted and should include documentation of all assumptions. 

Compact Impact Cost Estimates Contain Numerous Limitations: 

We found a number of limitations affecting the credibility of cost 
estimates in the compact impact reports (2004-2010) that we reviewed. 
(See appendix I for a description of our methodology in evaluating the 
cost estimates.) 

Accuracy: 

Definition of compact migrants. Several local government reporting 
agencies that responded to our inquiries did not define compact 
migrants according to the criteria in the amended compacts' enabling 
legislation and, as a result, may have either overcounted or 
undercounted costs. The legislation defines the population to be 
enumerated as persons, or those persons' children under the age of 18, 
who pursuant to the compacts are admitted to, or resident in, an 
affected jurisdiction as of the date of the most recently published 
enumeration. By counting compact migrants based on their ethnicity or 
language, agencies may have overcounted by including those present 
prior to the compacts; by identifying compact migrants by their 
citizenship, agencies may have undercounted, because they would have 
excluded compact migrants' U.S.-born children under the age of 18. For 
example, school administrative data from each of the affected 
jurisdictions show a potential for overcounting by identifying compact 
migrant children by means of ethnicity (as in Guam and the CNMI) or 
the language spoken at home (as in Hawaii).[Footnote 97] According to 
the 2003 Census survey data, approximately 32 percent of FAS citizens 
identified in the CNMI, 10 percent of those identified in Guam, and 13 
percent of those identified in Hawaii were not part of the defined 
impact population. Therefore, the number of children used to estimate 
impacts may also be overstated. 

Federal funding. Guam, Hawaii, and the CNMI, among other U.S. states 
and territories, receive federal funding for programs that compact 
migrants use; however, not all compact impact reports accounted for 
this stream of funding. For example, the Hawaii Department of 
Education reported as compact impact the cost of programs that federal 
funding had partially addressed.[Footnote 98] In addition, Guam and 
the CNMI's single audit reports show that these jurisdictions have 
received federal revenue from various agencies such as the U.S. 
departments of Health and Human Services (HHS), Agriculture, and 
Homeland Security. To the extent that revenue for these programs is 
based on population counts or data on usage, the presence of, and use 
of services by, compact migrants lead to federal offsets. For example, 
in fiscal years 2004 through 2008, Guam received an annual average of 
$1,027,825 from HHS for the Consolidated Health Centers program, an 
amount based partly on the number of beneficiaries in Guam. Based on 
Guam's resident and compact migrant populations in 2008, services to 
compact migrants accounted for a $112,942 share of that amount--equal 
to 16 percent of compact migrant impact costs reported by the Guam 
Bureau of Primary Care Services. However, in reporting impact costs, 
the Guam Bureau of Primary Care Services did not deduct the HHS 
funding that was used for compact migrants.[Footnote 99] 

Revenue. Multiple local government agencies that receive fees as a 
result of providing services to compact migrants did not consider them 
in their compact impact reports. For example, the CNMI Department of 
Public Health and Guam Department of Mental Health and Substance Abuse 
did not include payments received from compact migrants into their 
costs. This exclusion of revenue may cause an overstatement of the 
total impact reported. 

Capital costs. Many local government agencies, such as the CNMI Public 
School System, did not include capital costs in their annual compact 
impact reporting. This exclusion can cause an understatement of total 
costs of providing services to compact migrants.[Footnote 100] 

Per person costs. Many local government agencies estimated impact 
costs based on average, rather than specific, costs of providing 
services to compact migrants, possibly leading to under or 
overestimations. For example, the CNMI Department of Public Health 
based the cost of providing healthcare services to compact migrants on 
the number served out of the total patient load instead of totaling 
each patient's specific costs. However, other agencies more 
comprehensively accounted for costs by including additional compact 
impact expenses beyond the average costs. For example, the Hawaii 
Department of Education included language training costs in its 
reported per pupil expenditures. Alternatively, the CNMI Public School 
system did not include special services such as language training or 
translation which suggests an underestimation. 

Discretionary costs. Some compact impact costs reported by local 
government agencies were for benefits or services provided at the 
discretion of the affected jurisdiction.[Footnote 101] 

Data reliability. In one case, we found a discrepancy between the data 
reported and the data provided during this review. According to the 
Hawaii Department of Education, this discrepancy resulted from a 
system error that caused a double counting of Marshallese students 
over a 5-year period, which resulted in an overestimation of impact 
costs. For its 2011 impact report, the Department of Education said it 
excluded federal funds from its 2008 through 2011 compact impact costs 
and corrected the reporting error made regarding the number of compact 
students for 2006 through 2008. 

Adequate Documentation: 

Many local government agencies did not report their methodologies for 
estimating costs of providing services to compact migrants under the 
compacts. For example, the Hawaii Department of Human Services did not 
provide a detailed description of how it derived its estimates. As a 
result, it is difficult to determine whether the reported figures are 
accurate. Further, some agency methodologies vary between affected 
jurisdictions. For example, Guam prorates police costs based on the 
percentage of compact migrants in the total population, and the CNMI 
prorates its police costs based on the percentage of total arrests 
that are FAS citizens. The Guam Bureau of Statistics and Plans said it 
documented its methodologies in its 1995 compact impact report and 
applied these approaches in calculating its compact impact costs. 
However, these methodologies were not discussed in Guam's annual 
reports from 2004 to 2010 and were generally not used by the reporting 
agencies. 

Comprehensiveness: 

Hawaii has not submitted annual compact impact reporting each year and 
is not required to do so, but for those years when affected 
jurisdictions submitted impact reports to Interior, not all local 
government agencies included all compact impact costs. However, some 
agency costs were reported in subsequent fiscal year reports. For 
example, Hawaii did not provide estimated costs to Interior in 2005 
and 2006, although it included partial costs incurred in those years 
in its 2007 and 2008 reports. Without comprehensive data in the year 
they are submitted, the compact impact reports could understate 
Hawaii's total costs. In addition, compact impact reporting has not 
been consistent across affected jurisdictions. For example, Guam and 
the CNMI included the cost of providing police services, while Hawaii 
did not. 

[End of section] 

Appendix VII: Interior-Awarded Compact Impact Grants to Affected 
Jurisdictions from 2004 to 2011: 

Interior distributed the compact impact grants to the affected 
jurisdictions in 2004 through 2010 as follows: 

* From fiscal year 2004 through 2009, based on the results of 2003 
enumeration, Interior annually awarded approximately $14 million to 
Guam, $10.6 million to Hawaii, and $5.2 million to the CNMI. 

* In fiscal year 2010, having recalculated the division of funds based 
on the results of the 2008 enumeration,[Footnote 102] Interior awarded 
approximately $16.8 million to Guam, $11.2 million to Hawaii, and $1.9 
million to the CNMI. 

The amended compacts' enabling legislation and Interior's Office of 
Insular Affairs' Financial Assistance Manual guide the administration 
and management of compact impact grants. An official at Interior said 
the agency uses the same grant management process for compact impact 
funds as it does its other grants.[Footnote 103] To implement these 
requirements, Interior has reviewed and at times questioned whether 
the proposed uses of compact impact grant funds were in keeping with 
the amended compacts' enabling legislation. 

While the vast majority of Interior reviews resulted in approvals, 
Interior questioned some uses in Guam and the CNMI. Specifically: 

* Interior initially viewed Guam's fiscal 2010 request to fund a 
Community Pool Complex and Fitness Trail as only distantly connected 
to compact migrants. Ultimately, Interior accepted Guam's 
justification that it could improve the health of migrants by reducing 
obesity and provide a healthy outlet for youth, thereby reducing 
public safety concerns. 

* In fiscal year 2011, Interior approved the use of compact impact 
grant funds for Guam Memorial Hospital Authority (GMHA), but 
restricted their use to future purchases rather than paying past 
bills, contrary to previous Interior practice. According to an 
Interior official, this change was made in order to strengthen the 
link between migrant impacts and compact funds and to stop "bandaging" 
the chronic financial issues of GMHA.[Footnote 104] 

* In fiscal year 2006, Interior denied a CNMI grant proposal to use 
$400,000 for the Marianas Visitors Authority and $500,000 for 
Financial Control/Economic Recovery Initiatives. An Interior official 
said the agency did not retain documentation of the specific nature of 
these grant requests or why it denied them. 

As of August 2011, Guam had approximately $14.2 million in compact 
impact grant funds available from fiscal years 2004 to 2011 that it 
had yet to draw down from Interior. Both Hawaii and the CNMI have 
fully drawn down prior fiscal year funds. 

See table 9 for a complete list of Interior compact impact grant 
awards by jurisdiction and fiscal year. 

Table 9: Compact Impact Grant Awards to Affected Jurisdictions, 2004- 
2011: 

Year: FY 2011; 

Guam Compact Impact Grants: Guam School Leaseback Program and Addendum; 
Award Amount: $7,100,000. 

Guam Compact Impact Grants: Judiciary of Guam-case management system 
procurement; 
Award Amount: Year: $3,777,026. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority--medical 
equipment purchase; 
Award Amount: Year: $2,500,000. 

Guam Compact Impact Grants: University of Guam-architectural and 
engineering design of student services center and school of 
engineering building; 
Award Amount: Year: $1,400,000. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-medical and pharmaceutical supplies purchase; 
Award Amount: Year: $750,000. 

Guam Compact Impact Grants: Department of Corrections-standby 
generators purchase; 
Award Amount: Year: $500,000. 

Guam Compact Impact Grants: Department of Corrections-electronic cell 
locking system upgrade; 
Award Amount: Year: $300,000. 

Guam Compact Impact Grants: Department of Youth Affairs Facilities 
Improvements; 
Award Amount: $250,000. 

Guam Compact Impact Grants: Department of Integrated Services for 
Individuals with Disabilities-permanent injunction projects; 
Award Amount: $250,000. 

Guam Compact Impact Grants: Total award; 
Award Amount: $16,827,026. 

Year: FY 2010; 

Guam Compact Impact Grants: Guam School Leaseback Program; 
Award Amount: $6,100,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority Vendor 
Payables; 
Award Amount: $3,500,000. 

Guam Compact Impact Grants: Department of Parks and Recreation 
Northern Sports Recreation Complex; 
Award Amount: $2,700,000. 

Guam Compact Impact Grants: Guam School Leaseback Addendum; 
Award Amount: $1,000,000. 

Guam Compact Impact Grants: Guam Fire Department Equipment (Fire 
Trucks Purchase); 
Award Amount: $750,000. 

Guam Compact Impact Grants: Guam Police Department Equipment (Patrol 
Vehicles Purchase); 
Award Amount: $527,026. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-pharmaceutical supplies purchase; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority--medical 
supplies purchase; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-permanent injunction projects; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority--medical 
supplies purchase #2; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Youth Affairs Building 
Renovation and Equipment Purchase; 
Award Amount: $250,000. 

Guam Compact Impact Grants: Total award; 
Award Amount: $16,827,026. 

Year: FY 2009; 

Guam Compact Impact Grants: Guam School Leaseback Program and Addendum; 
Award Amount: $7,100,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority-- 
pharmaceuticals and equipment purchase; 
Award Amount: $3,142,322. 

Guam Compact Impact Grants: Guam Fire Department-equipment purchase; 
Award Amount: Year: $1,000,000. 

Guam Compact Impact Grants: Guam Police Department Forensic Crime Lab-
equipment purchase; 
Award Amount: $1,000,000. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-pharmaceuticals and medical supplies purchase; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-permanent injunction project; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Integrated Services for 
Individuals with Disabilities-permanent injunction projects; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Public Works-solid waste 
heavy equipment purchase; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority 
Operational Assessment and Feasibility Study; 
Award Amount: $286,657. 

Guam Compact Impact Grants: Total award; 
Award Amount: $14,528,979. 

Year: FY 2008; 

Guam Compact Impact Grants: Guam School Leaseback Program; 
Award Amount: $6,100,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority-- 
pharmaceuticals, medical supplies and equipment purchase; 
Award Amount: $5,000,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority-- 
pharmaceuticals, medical supplies and equipment purchase; 
Award Amount: $1,992,303. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-pharmaceuticals, medical supplies and equipment; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Integrated Services for 
Individuals with Disabilities-permanent injunction projects; 
Award Amount: $287,000. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-personal care attendant pilot program; 
Award Amount: $213,000. 

Guam Compact Impact Grants: Total award; 
Award Amount: $14,092,303. 

Year: FY 2007; 

Guam Compact Impact Grants: Guam School Leaseback Program; 
Award Amount: $6,100,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority-- 
pharmaceutical supplies and equipment purchase; 
Award Amount: $6,242,322. 

Guam Compact Impact Grants: Department of Integrated Services for 
Individuals with Disabilities -permanent injunction projects; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-pharmaceutical supplies and equipment purchase; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Corrections-phase II fire 
sprinkler system; 
Award Amount: $500,000. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-therapeutic group home services; 
Award Amount: $230,000. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-psychotropic medication purchase; 
Award Amount: $170,000. 

Guam Compact Impact Grants: Total award; 
Award Amount: $14,242,322. 

Year: FY 2006; 

Guam Compact Impact Grants: Guam School Leaseback Program; 
Award Amount: $6,100,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority--medical 
personnel and equipment purchase; 
Award Amount: $2,478,986. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority Vendor 
Payables; 
Award Amount: $1,629,014. 

Guam Compact Impact Grants: Department of Integrated Services for 
Individuals with Disabilities-programs and facility improvements; 
Award Amount: $1,000,000. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-pharmaceuticals purchase; 
Award Amount: $1,000,000. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-permanent injunction projects; 
Award Amount: $806,322. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse--third floor main building renovations; 
Award Amount: $684,068. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-psychotropic medication purchase; 
Award Amount: $200,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority--clinical 
health services for diabetes program; 
Award Amount: $150,000. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-fire protection system; 
Award Amount: $115,932. 

Guam Compact Impact Grants: Stray Animal Enhancement Program; 
Award Amount: $78,000. 

Guam Compact Impact Grants: Total award; 
Award Amount: $14,242,322. 

Year: FY 2005; 

Guam Compact Impact Grants: Guam School Leaseback Program; 
Award Amount: $6,100,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority--
pharmaceuticals payments; 
Award Amount: $3,005,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority-- 
pharmaceuticals and supplies purchase; 
Award Amount: $2,211,600. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-permanent injunction project: equipment for therapeutic group 
home; 
Award Amount: $916,000. 

Guam Compact Impact Grants: Guam Fire Department-equipment purchase; 
Award Amount: $538,005. 

Guam Compact Impact Grants: Department of Mental Health and Substance 
Abuse-acquisition of therapeutic group home for adolescents; 
Award Amount: $412,000. 

Guam Compact Impact Grants: Department of Public Works-equipment 
(vehicles/heavy equipment purchase); 
Award Amount: $359,717. 

Guam Compact Impact Grants: Department of Youth Affairs-building 
improvement and equipment purchase; 
Award Amount: $350,000. 

Guam Compact Impact Grants: Guam Police Department-equipment 
(ballistic vests purchase); 
Award Amount: $200,000. 

Guam Compact Impact Grants: Department of Public Works Equipment (two 
backhoes purchase); 
Award Amount: $150,000. 

Guam Compact Impact Grants: Total award; 
Award Amount: $14,242,322. 

Year: FY 2004; 

Guam Compact Impact Grants: Guam Memorial Hospital Authority-
pharmaceuticals and supplies purchase; 
Award Amount: $3,584,010. 

Guam Compact Impact Grants: Purchase of 40 School Buses; 
Award Amount: $3,200,000. 

Guam Compact Impact Grants: Guam Police Department-building 
improvement and equipment purchase; 
Award Amount: $2,837,000. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-pharmaceuticals and medical supplies purchase; 
Award Amount: $1,800,000. 

Guam Compact Impact Grants: Guam Memorial Hospital Authority--building 
improvement and equipment purchase; 
Award Amount: $1,500,000. 

Guam Compact Impact Grants: Department of Public Health and Social 
Services-building improvement and equipment purchase; 
Award Amount: $764,238. 

Guam Compact Impact Grants: Department of Corrections-fire alarm and 
sprinkler improvement; 
Award Amount: $300,000. 

Guam Compact Impact Grants: Guam Fire Department-ambulances and 
equipment purchase; 
Award Amount: $257,074. 

Guam Compact Impact Grants: Total award; 
Award Amount: $14,242,322. 

Year: FY 2011; 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,157,234. 

CNMI Compact Impact Grants: Department of Public Health; 
Award Amount: $536,744. 

CNMI Compact Impact Grants: Department of Corrections; 
Award Amount: $154,698. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $44,616. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $37,151. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $1,930,443. 

Year: FY 2010; 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,157,234. 

CNMI Compact Impact Grants: Department of Public Health; 
Award Amount: $414,453. 

CNMI Compact Impact Grants: Department of Corrections; 
Award Amount: $154,698. 

CNMI Compact Impact Grants: Northern Marianas College; 
Award Amount: $122,291. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $44,616. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $37,151. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $1,930,443. 

Year: FY 2009; 

CNMI Compact Impact Grants: Public School System; 
Award Amount: $2,110,000. 

CNMI Compact Impact Grants: Department of Public Health; 
Award Amount: $1,125,000. 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,000,000. 

CNMI Compact Impact Grants: Department of Corrections; 
Award Amount: $415,000. 

CNMI Compact Impact Grants: Northern Marianas College; 
Award Amount: $330,000. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $120,000. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $71,914. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $5,171,914. 

Year: FY 2008; 

CNMI Compact Impact Grants: Public School System; 
Award Amount: $2,000,000. 

CNMI Compact Impact Grants: Department of Public Health; 
Award Amount: $1,240,000. 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,000,000. 

CNMI Compact Impact Grants: Department of Corrections; 
Award Amount: $420,000. 

CNMI Compact Impact Grants: Northern Marianas College; 
Award Amount: $307,437. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $100,000. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $50,000. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $5,117,437. 

Year: FY 2007; 

CNMI Compact Impact Grants: Public School System; 
Award Amount: $2,000,000. 

CNMI Compact Impact Grants: Department of Public Health; 
Award Amount: $1,371,914. 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,000,000. 

CNMI Compact Impact Grants: Northern Marianas College; 
Award Amount: $350,000. 

CNMI Compact Impact Grants: Department of Corrections; 
Award Amount: $300,000. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $100,000. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $50,000. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $5,171,914. 

Year: FY 2006; 

CNMI Compact Impact Grants: Public School System Renovations; 
Award Amount: $2,000,000. 

CNMI Compact Impact Grants: Department of Public Health Hospital; 
Award Amount: $1,431,914. 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,200,000. 

CNMI Compact Impact Grants: Department of Corrections; 
Award Amount: $350,000. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $100,000. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $50,000. 

CNMI Compact Impact Grants: Department of Public Health Mental Health 
Services; 
Award Amount: $40,000. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $5,171,914. 

Year: FY 2005; 

CNMI Compact Impact Grants: Department of Public Health; 
Award Amount: $3,698,315. 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,004,894. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $242,730. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $153,826. 

CNMI Compact Impact Grants: Department of Public Health Mental Health 
and Social Services; 
Award Amount: $72,149. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $5,171,914. 

Year: FY 2004; 

CNMI Compact Impact Grants: Department of Public Health; 
Award Amount: $3,698,315. 

CNMI Compact Impact Grants: Department of Public Safety; 
Award Amount: $1,004,894. 

CNMI Compact Impact Grants: Division of Youth Services; 
Award Amount: $242,730. 

CNMI Compact Impact Grants: Office of the Public Defender; 
Award Amount: $153,826. 

CNMI Compact Impact Grants: Department of Public Health Mental Health 
and Social Services; 
Award Amount: $72,149. 

CNMI Compact Impact Grants: Total award; 
Award Amount: $5,171,914. 

Year: FY 2011; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $11,228,742. 

Year: FY 2010; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $11,228,742. 

Year: FY 2009; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $10,571,277. 

Year: FY 2008; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $10,504,556. 

Year: FY 2007; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $10,571,277. 

Year: FY 2006; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $10,571,277. 

Year: FY 2005; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $10,571,277. 

Year: FY 2004; 
Hawaii Compact Impact Grants: Department of Health and Human Services-
health care programs; 
Award Amount: $10,571,277. 

Source: U.S. Department of the Interior, Office of Insular Affairs. 

[End of table] 

[End of section] 

Appendix VIII: Comments from the Department of the Interior: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

United States Department of the Interior: 
Office Of The Secretary: 
Washington, DC 20240: 

October 24, 2011: 

Mr. David B. Gootnick: 
Director: 
International Affairs and Trade: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Gootnick: 

The Department of the Interior (Department) views the draft report GAO-
12-64, "Compact of Free Association: Improvements Needed to Assess and 
Address Growing Migration" (Report) as a useful and valiant attempt to 
fairly quantify the impact of immigrants from the Freely Associated 
States (FAS) on the affected jurisdictions of Hawaii, the Territory of 
Guam and the Commonwealth of the Northern Marianas since the 
implementation of the Compacts of Free Association (COFA) in 1986. We 
appreciate the new information contained in the Report, especially the 
location of population centers of FAS citizens throughout the United 
States. We note as well that GAO has encountered the same difficulties 
that the Department and other executive agencies have found in 
discovering valid data on employment, taxation and consumption of 
services by FAS immigrants. 

The Report demonstrates that the impact of immigration from FAS 
countries has an economic cost to the affected areas greater than the 
$30 million annually granted those areas under a permanent 
appropriation. The Department recognizes this impact and is working 
with other Federal agencies, the affected jurisdictions and the FAS 
governments to find ameliorative responses. It is a complex problem 
for which existing law and the Compact itself offer no easy solutions. 
We appreciate GAO's contribution to finding answers. 

We have two recommendations to GAO we wish to see reflected in the 
Report. First, we believe that GAO should clarify that the purpose of 
Compact impact funds is "to aid in defraying carts incurred by
the affected jurisdiction as a result of increased demands placed" on 
local services, and were not intended to fully reimburse the affected 
jurisdictions. Sprinkled throughout the Report are the terms 
"compensation" and "reimbursement" which imply that the Compact impact 
funds were to he equivalent to the affected jurisdiction's costs in 
providing services. This is clearly not the intent of the law. P.L.
108-188 permanently appropriated $30 million annually from 2004 
through 2023 without provision for inflation, and used limiting 
language, "aid in defraying", to establish a limit on Federal 
contributions for Compact impact in these areas. We believe this 
clarification would assist Congressional, state and territorial 
leaders in placing the Federal role in Compact impact in proper 
context. [See comment 1] 

Second, the Report implies that Compact sector grant resources can be 
shifted from providing assistance to the FAS governments in situ, to 
providing assistance to FAS expatriates living in the affected 
jurisdictions. There is nothing in the record of the Compact 
negotiations, the agreement itself, or in the law to support this 
implication. Funds appropriated in P.L. 108-183 arc to support 
specific sections of the Compact providing sector grants and for other 
purposes. Each of the sectors, in turn, supports FAS government 
activities in-country. The few examples of training programs taking 
place outside of the FAS are the result of the FAS governments' 
choices in the use of sector grant funds. Without changes to existing 
law and to the Compact, no shifting of resources from the FAS to the 
affected areas can be considered. We also believe that shifting 
Compact resources would have ruinous effects on the affected FAS 
sector activities and to the FAS economies. [See comment 2] 

With regard to the four actions recommended to be taken by the 
Secretary of the Interior, we offer the following:  

* In order to select the most appropriate approach for its next 
enumeration of Compact migrants, filly consider the strengths and 
limitations of its preliminary approach for 2013, weighing the costs 
of the approach for the need for data that will he fair as well as 
useful to the affected jurisdiction. 

The Department will consult with the Census Bureau on the various 
statistical methods extant for this sort of analysis, and will review 
the suggestions raised in the Report. We consider the expertise of the 
Census Bureau to be the standard, and we respect their advice. The 
question of cost will be significant in 2013. P.L. 108-188 allocates 
only $300,000 for this purpose, an amount that was insufficient to 
perform the April 2009 report. In the current fiscal climate, it will 
be difficult to support a more extensive enumeration from within the 
Department's Office of  Insular Affairs' budget. 

* In order to strengthen its ability to collect, evaluate, and 
transmit reliable information to Congress, disseminate guidelines to 
the affected jurisdiction that adequately address concepts essential 
to producing reliable impact estimates, and call for the affected 
jurisdictions to apply these guidelines when developing compact impact 
reports. 

P.L. 108-188 invites, but does not require, the governors of the 
affected jurisdiction to provide their comments with respect to 
impacts on their respective areas. To date, the Department has chosen 
not to instruct the governors on the contents of their report so as 
not to intrude into local prerogatives. Given, however, the 
suggestions contained in the Report such as the limitations of cost 
data and even the definitions of who is a compact migrant, the 
Department will advise the governors of possible guidelines to develop 
compact reports. The governors will remain free to accept these 
guidelines or provide their own comments in a manner that best suits 
them. 

* In order to promote the most effective use of compact impact grants, 
work with the affected jurisdiction to evaluate the current use of 
grant funds and consider alternative uses of these grants to reduce 
compact impact. 

P.L. 108-188 authorizes very broad uses of Compact impact funds to 
give the affected areas flexibility in their uses. indeed, the 
universe of impacted areas is quite broad and the amount of impact 
funds is insufficient to address all aspects of impact. in this 
circumstance, the Department has chosen to respect the funding 
priorities of the governors of the affected areas, as we believe the 
law intends, and we do not believe any practical gains can be made by 
proposing alternative uses. We recommend that this action not be 
included in the final report. [See comment 3] 

* In order to help mitigate compact impact and better assist 
Micronesian and Marshallese citizens  who migrate to the United 
States, work with the US/Micronesia and US-Marshall Islands
 committee to consider uses of sector grants that would address the 
needs of Micronesian and Marshallese citizens living in the United 
States as compact migrants and respond to the concerns of the affected 
jurisdiction. 
 
The Compact agreements outline with some specificity the appropriate 
uses of Compact funds. As we noted earlier, we also believe that 
Compact funds are limited to use within the territory of
the FAS. However, we do agree that some activities may be related both 
to established Compact to that better immigrants live sector grant 
priorities and programs would prepare potential to and work in the 
U.S, or facilitate the exchange of information between the FAS and the 
affected jurisdictions in matters regarding health and education. We 
believe the bi-lateral committees will consider uses that meet both 
goals. [See comment 4] 

We appreciate the opportunity to comment on the draft report and look 
forward to its final publication. If you have any questions, please 
feel free to communicate with me at 202-208-6816. Or you or your staff
may wish to communicate with Tom Bussanich, OIA's Director of Budget 
and Grants Management at 202-208-5947 or by email at 
. 

Sincerely, 

Signed by: 

Nikolao Pula: 
Director of insular Affairs: 

The following are GAO's specific responses to the comments in the 
Department of the Interior's letter dated October 24, 2011. 

GAO Comments: 

1. The Department of the Interior suggested that our report's use of 
the terms "compensation" and "reimbursement" to describe compact 
impact funds could give the impression that these funds were intended 
to fully reimburse the affected jurisdictions for their added expenses 
when the amended compacts' enabling legislation states that compact 
impact grants are "to aid in defraying costs incurred by affected 
jurisdictions as a result of increased demands placed on health, 
educational, social, or public safety services or infrastructure 
related to such services due to the residence in affected 
jurisdictions" of compact migrants. We have modified the text to make 
our characterization of the act's intent clearer. Also in response to 
this comment, as well as comments received from Guam, we have cited 
additional provisions of the amended compacts' enabling legislation 
that authorize funds to address compact impact. As the affected 
jurisdictions may view the law as implying a reimbursement, we have 
kept such a characterization when it reflects the viewpoint of the 
affected jurisdiction. 

2. The Department of the Interior stated that the record of the 
compact negotiations, the compact agreements, and the amended 
compacts' implementing legislation do not support the use of sector 
grants to provide assistance to FAS expatriates living in affected 
jurisdictions. Interior stated that the compact provides sector grants 
to support FAS government activities in-country and that the few 
training programs taking place outside of the FAS are the result of 
the FAS governments' choices in the use of sector grants. We agree 
with Interior that the sector grants listed in the compacts are to 
support the governments of the FSM and the Marshall Islands by 
providing grants in certain sectors such as health care and education; 
however, we note that the compacts allow grants to fund other sectors 
as mutually agreed and we have added this text to our description of 
compact economic assistance. Currently, limited FSM compact grant 
funds are being used to support worker training in Guam, addressing a 
concern of compact migrants in Guam as well as the Guam government. 
According to the Center for Micronesian Empowerment, approximately 45 
percent of its trainees in Guam are compact migrants residing in Guam. 

3. The Department of the Interior did not agree with our 
recommendation that it work with affected jurisdictions to evaluate 
the current use of compact impact grant funds and consider alternative 
uses. Interior observed that the amended compacts' enabling 
legislation authorizes broad uses and that it has chosen to respect 
the priorities of governors. Interior further stated that it does not 
believe there would be any practical gains from proposing alternative 
uses. We believe this position overlooks opportunities to respect the 
priorities of the governors while at the same time working with the 
governors to review their current use of funds and consider 
alternatives uses. In the course of our review we identified 
alternative grant uses for consideration. We found that government 
officials, service providers, and compact migrants in the affected 
jurisdictions identified a significant need for language and cultural 
assistance, job training, and improved access to basic services for 
compact migrants. The sources suggested that migrant needs could be 
addressed by, for example, establishing centers that offer such 
services. This may also help reduce some of the negative impact from 
compact migration. For example, more translators could result in more 
effective health treatment. 

Other alternative uses may also offer practical gains. For example, 
health experts have advocated for the adoption of primary health care 
as a more cost-effective strategy for providing health care in the 
Pacific Islands.[Footnote 105] This adoption would address the need 
for preventive care among Micronesians and Marshallese in Hawaii--
studies have shown that the Marshallese in Hawaii do not generally 
seek preventive care and only seek professional health care when they 
experience a certain level of pain.[Footnote 106] 

4. The Department of the Interior stated that it believes compact 
sector grants are limited to use within the FAS; however, Interior 
agreed that some activities may be related both to sector grant 
priorities and to programs that would better prepare migrants to live 
and work in the United States. Interior stated that our report implies 
that compact sector grant funds should be shifted from providing 
assistance to the FAS governments to providing assistance to FAS 
citizens living in affected jurisdictions, an action that Interior 
sees as inconsistent with the compacts and their enabling legislation. 
We expect that compact sector grant awards will be provided consistent 
with the terms of the compacts and the amended compacts' enabling 
legislation; we do not intend to imply that funds should be shifted 
from the FAS governments to FAS migrants. In response to Interior's 
concern, we clarified that our findings and recommendation highlight 
the opportunity for the joint management committees to consider the 
use of sector grants to the FSM and Marshall Islands in ways that 
address the concerns of FAS citizens--whether they are in the FAS or 
in U.S. areas--and the concerns of the affected jurisdictions. The 
recommendation supports consideration of the use of sector grants in 
ways that respond to the concerns of FSM and Marshall Islands migrants 
and the affected jurisdictions. 

[End of section] 

Appendix IX: Comments from the Census Bureau: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

United States Department Of Commerce: 
Economics and Statistics Administration: 
Office Of The Director: 
U.S. Census Bureau
Washington, DC 20233-0001: 
 
October 27, 2011: 

Mr. David B. Gootnick: 
Director: 
International Affairs and Trade: 
U.S. Government Accountability Office: 
Washington, DC 20548:  

Dear Mr. Gootnick:  

Please find enclosed the U.S. Department of Commerce's comments on the 
'U.S. Government Accountability Office's (GAO) draft report titled 
"Compacts of Free Association: Improvements Needed to Assess and 
Address Growing Migration" (GAO-I2-64). The comments are grouped into 
two sections; general comments that address higher-level issues and 
recommendations, and more specific comments that address technical 
issues.  

Thank you for providing the opportunity to review the draft report and 
we hope you will find our comments helpful in completing the final 
report.  

Sincerely, 

Signed by:   

Robert M. Groves: 
Director: 
 
Enclosure: 

[End of letter] 

"Compacts of Free Association: Improvements Needed to Assess and 
Address Growing Migration" (GAO-12-64): 

[Pages in the draft report may differ from those in this report] 

General Comments: 

1. Regarding the content of the 2008 surveys, the Census Bureau wants 
to emphasize that the content was purposely chosen to be the content 
required to enumerate the Compacts of Free Association (COFA) 
migrants. This was approved by the Department of Interior and done to 
minimize costs and maximize respondent participation. [See comment 1] 

2. The report states that Hawaii, Guam, and the Commonwealth of the 
Northern Mariana Islands (CNMI) surveys were not comparable in terms 
of reliability. In fact, the 2008 Guam and CNMI surveys were designed 
to produce estimates of COFA migrants with a similar coefficient of 
variation to the American Community Survey (ACS) estimates for Hawaii. 
[See comment 2] 

3. The primary reason the Census Bureau indicated that the snowball 
approach would not meet OMB standards was standard 4,1, which requires 
estimates of error. A snowball census will virtually always undercount 
and unless a separate evaluation effort is also conducted, the degree 
of the undercount is unknown. Thus, it does not meet that standard. 

4. The report recognizes that the Department of Interior is 
considering a two-pronged approach for 2013 — using the 2010 decennial 
census results for Guam and CNMI and the ACS for Hawaii — as an 
alternative to conducting surveys in Guam and CNMI as was done in 
2008. The Census Bureau recommends that the Department of Interior 
adopt the two-pronged approach for the 2013 enumeration of compact 
migrants, drawing from the 2010 Decennial Census and ACS. This would 
provide the required estimates in a more cost effective manner. [See 
comment 3] 

Specific Comments: 

1. "What GAO Found" 2nd paragraph--The phrase "The 2008 approach 
allowed for determining the precision of the estimates but did not 
yield comparable results across jurisdictions ..." is misleading. 
There are some time-related limitations on comparing the Hawaii 
estimate to the Guam and CNMI estimates, which may add some bias 
depending on the actual change over time in Hawaii, but to conclude 
they are not comparable at all is overstated. [See comment 2] 

2. "What GAO Found" 2nd paragraph -- "Interior and Census officials 
have a preliminary plan for the required 2013 enumeration but have not 
determined its costs or assessed its strengths and limitations." The 
report should clarify that the Department of Interior (in consultation 
with the Census Bureau) will determine the final plans for 2013. 

3. Page 18, Approach Used in 2008 Had Strengths and Limitations— 
"...limiting the usefulness of the 2008 data for purposes other than 
the required enumeration." See General Comment #1. [See comment 1] 

4. Page 18, footnote 27 — indicates that the 2008 surveys did not 
cover the homeless. The surveys were designed to select blocks and 
then enumerate everyone in the block, including the homeless 
population. [See comment 4] 

5. Page 19, first bullet point -- "The effect of the earlier time 
frame is to undercount the compact migrants in Hawaii relative to the 
counts in Guam and the CNMI". There is no evidence to support this 
conclusion. [See comment 5] 

6. Page 19, third bullet point -- "In 2008, Census did not collect ... 
beyond that required for the enumerations." See General Comment #1. 
[See comment 1] 

7. Page 20, top — "The ACS for 2005-2007 identified a cumulative total 
of 295 compact migrants from which Census estimated the total reported 
population." That is why the Census Bureau used three years worth of 
data from the ACS to increase the reliability of the estimate of the 
number of compact migrants in Hawaii and designed the Guam and
CNMI surveys to have the same level of reliability as three years of 
ACS data. 

8. Page 20 — Regarding the sentence "Both Guam and CNMI officials 
stated that the compact migrant population changed addresses 
frequently, potentially affecting the sampling methodology and leading 
to a miscount." Such movement would not produce bias in the surveys as 
designed. It may reduce the efficiency of the block stratification 
using 2000 Census data, but that loss of efficiency was factored into 
sample size selection to ensure the desired accuracy. The Census 
Bureau also gave both Guam and CNMI an opportunity to provide local 
information that might improve the accuracy. They did not produce this 
information before the design had to be finalized. [See comment 6] 

9. Page 21 -- "Census would again deploy a two-pronged approach, using 
the 2010 decennial census results for Guam and the CNMI and the ACS 
for Hawaii." The advantage of this approach is that it is cost 
effective since no additional data collection is required and that the 
2010 Census for Guam and CNMI have similar content as the ACS that 
will be able to identify COFA migrants. 

10. Page 22, second bullet point -- "The change in enumeration method 
... would limit the comparability of the 2008 and 2013 enumerations." 
Both methods would provide a comparable count, which is what is 
required for the purpose of determining funding. [See comment 7] 

11. Page 51, Census Data Provide Varying Estimates of Compact Migrants 
in Arkansas. —The estimates described in this section are not based on 
the same criteria and therefore should not be compared. ACS 
tabulations of compact migrants take into account very specific rules 
regarding place of birth, year of migration and status of parent. This 
is a different basis from self-identification on the race question on 
the 2010 census form or on school enrollment forms. [See comment 8] 

12. Page 59, footnote 85 — The Census Bureau generally provides 
coverage rates when using a list frame. This survey was a sample of 
blocks that geographically cover the target jurisdiction followed by 
list-enumerate of the block, so coverage rates are not provided. 

13. Page 60, Reaching Target Population -- This section indicates that 
"The AS was not designed to make estimates of a population as small as 
the compact migrants. Additional sampling is needed to make reliable 
estimates of a population this small." However, one of the references 
in footnote 86 on page 60 (Alexander and Navarro, page 1) indicates 
that "a priority objective of the ACS design has been to provide good 
information about smaller groups." Whether or not one can conclude 
that the ACS cannot provide reliable estimates depends on which 
definition of "reliable" is used. The reliability of the ACS estimate 
for Hawaii was at a similar level to the reliability of the survey 
estimates for Guam and CNMI. [See comment 9] 

14. Page 61, Nonresponse rate, right column — "However, Census did not 
provide an unweighted response rate." The OMB standard, as noted, is 
to include only weighted response rates, as these are meaningful to 
users of the data. Unweighted response rates may be used internally 
for the purposes of operational examination. It is not usual to 
establish them. [See comment 10] 

15. Page 61, Nonresponse rate, right column — "Proxy respondents were 
used; ... indicating that the response rate is overstated." Proxy 
responses are generally accepted as a "response" in household surveys 
and included in the response rate. [See comment 11] 

16. Page 61, Nonresponse bias, and Page 62, Collection strategy and 
content -- The 2003 survey (left column) had similar issues as 
highlighted for the 2008 surveys (right column), but they are not 
listed for the 2003 survey. [See comment 12] 

17. Page 63, Variance Estimation. -- The final weights were used when 
calculating the variance estimation, which may not have been clear in 
the documents the Census Bureau provided. Also, the weights for the 
original and supplemental sample blocks were calculated using the 
joint probability of selection and ended up with equal weights
within each stratum. This was stated in the weighting and variance 
documentation. [See comment 13] 

The following are GAO's responses to comments from the Census Bureau 
letter dated October 27, 2011. 

GAO Comments: 

1. Census emphasized that the migrant survey content was purposely 
chosen to enumerate compact migrants while minimizing costs and 
maximizing respondent participation. As our report notes, however, 
collecting only those data needed to enumerate migrants limited the 
collection of data that stakeholders such as affected jurisdictions 
would have found useful. 

2. Census stated that, in contrast to our report's findings, the 2008 
Guam and CNMI surveys were designed to produce estimates with a 
similar coefficient of variation to the ACS estimates for Hawaii. 
However, the 2008 Guam and CNMI estimates are point-in-time estimates 
while the ACS is a multiyear estimate. As Census guidance on 
interpreting the ACS multiyear estimates states, "The ACS estimates 
the average of a characteristic over the year or period years, as 
opposed to the characteristic at a point in time" and "When comparing 
estimates across geographies or subpopulations, users should compare 
the same period length for each estimate."[Footnote 107] Our findings 
do not suggest that the 2008 Guam and CNMI surveys are not comparable 
with the ACS estimates for Hawaii in terms of reliability, but rather 
are not comparable in terms of their sampling methods and reporting 
period. We show that the estimates have similar relative errors, as 
presented in appendix V. If the reported precision for the Guam and 
CNMI surveys is accurately estimated, and includes proxy respondents, 
the estimates have similar levels of precision. 

3. Census recommended that the Department of the Interior adopt the 
two-pronged approach described in our report for the 2013 enumeration 
of compact migrants and stated that the approach would provide cost- 
effective required estimates. We agree that the low cost is a strength 
of this approach. As our report notes, however, the 2013 two-pronged 
approach will have limitations such as using data from different time 
periods, limited comparability with prior data, and limited collection 
of demographic data. 

4. Census referred to a footnote in our draft report that indicated 
that the homeless population was not represented in the 2008 surveys. 
We have moved this discussion to appendix V and included an assessment 
of the varying coverage of the homeless population of the 2003 
snowball, ACS, and 2008 migrant survey in Guam and the CNMI. 

5. Census disagreed with our statement that the effect of using an 
earlier time frame of data in Hawaii relative to Guam and the CNMI 
results in an undercount of compact migrants in Hawaii relative to 
Guam and the CNMI. However, as our report notes, migration is ongoing, 
with approximately 7,000 persons estimated to have left the FSM and 
the Marshall Islands in 2007 and 2008. Other available data also 
indicate that the migrant population is growing. Because the Hawaii 
data do not include 2008 and the Guam and CNMI data are from the 
closing months of 2008, nearly a year of additional migration is 
captured in the Guam and CNMI totals that is not included in the 
Hawaii ACS data. Alexander and Navarro (2003) show that even the upper 
bound of the ACS multiyear confidence interval, an amount that is 
greater than the estimate, can lag behind the actual value for a 
growing small population at a given point in time.[Footnote 108] 

6. Census stated that the frequent changing of address by the compact 
migrant population, cited by Guam and CNMI officials as potentially 
leading to a miscount, would not produce bias in the surveys as 
designed. We agree with Census' comment that inaccurate migrant counts 
in the sample design would lead to lack of efficiency and not bias. 
However, we note that researchers inside and outside the Census Bureau 
studying the foreign-born population agreed that an assumption of 
complete coverage of legal immigrants and temporary migrants in the 
2000 Census[Footnote 109] was unreasonable indicating the potential 
for coverage error and bias of the estimates based on the 2000 Census 
sampling frame. Further, migrants, especially those who frequently 
change address, are not only hard to count in the census, but they 
also are less likely to participate in other surveys, indicating the 
potential for nonresponse bias. Census further stated that it gave 
both Guam and CNMI an opportunity to provide local information that 
might improve the accuracy but that neither produced this information 
before the design had to be finalized. However, we note that both Guam 
and CNMI officials stated that, from their perspective, implementation 
of the survey was rushed and they had only limited opportunity to 
provide such input. 

7. Regarding our statement about the change in enumeration method 
limiting the comparability of the 2008 and 2013 enumerations, Census 
stated that both methods would provide a comparable count, which is 
what is required for the purpose of determining funding. We note that 
the estimates across jurisdictions, within an enumeration, are not 
comparable. We note that estimates across enumerations are not 
comparable due to changing methodology and the lack of use of a method 
that is statistically designed to measure change over time. 

8. Census asserted that its varying estimates of compact migrants in 
Arkansas are not based on the same criteria and therefore should not 
be compared. We agree that the surveys have different bases for 
identification and have identified several reasons for these 
differences in appendix IV. However, we have also noted Arkansas' 
concerns about the accuracy of the ACS data. 

9. Census disagreed with our observation that the ACS was not designed 
to make estimates of a population as small as the compact migrants and 
notes that concluding that the ACS cannot provide reliable estimates 
depends on which definition of "reliable" is used. We note that the 
Census Bureau did not determine the level of precision, or 
reliability, necessary for these estimates to be used for funding. As 
we show in appendix III, while the ACS can be used to detect the 
presence of compact migrants, the smaller the population, the less 
reliable the estimates will be, as indicated by the wide confidence 
intervals. In some cases, the estimates are so unreliable that we 
suppressed them. 

10. In response to our observation that Census did not provide an 
unweighted response rate, Census stated that it is not usual for the 
agency to publish unweighted response rates. Our review of OMB 
Standards and Guidelines for Statistical Surveys indicates that both 
unweighted and weighted response rates should be calculated and 
reported.[Footnote 110] However, an unweighted response rate was not 
provided in Census Survey Documentation that we received for review. 

11. Census disagreed with our statement that the use of proxy 
respondents indicates an overstatement of the response rate and 
asserts that proxy responses are generally accepted in household 
surveys and included in the response rate. Proxy respondents are 
substitutions for the intended sample member, and Census acknowledged 
that proxy responses are a potential source of nonsampling error due 
to the proxy respondent's potential lack of knowledge of the sample 
respondent's information. OMB guidelines and standards call for the 
calculation of response rates without substitutions, as well as 
overall response rates that include substitutions.[Footnote 111] 

12. Census stated that the issues of nonresponse bias, as well as 
collection strategy and content, that we highlight regarding the 2008 
survey effort were also present in the 2003 survey but are not listed 
for the 2003 survey. For the 2003 survey, we had no documentation of 
the nonresponse bias or the collection strategy and content 
information related to personal interviewers leaving contact 
information. We have noted Census's comments in the report. 

13. Census stated that final weights were used when calculating the 
variance estimates. While we acknowledge that final weights, including 
a nonresponse adjustment factor, were used when calculating variances, 
Census documentation does not indicate that variance estimates 
properly accounted for the variability due to the nonresponse 
adjustment factor, such as through the use of replicate weight 
methodologies, and thus will likely result in an underestimate of the 
variance. 

[End of section] 

Appendix X: Comments from the Government of Hawaii: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

Executive Chambers: 
Neil Abercrombie, Governor: 
Honolulu: 

October 19, 2011: 

David Gootnick: 
Director: 
International Affairs and Trade: 
U.S. General Accounting Office: 
441 G Street N.W. 
Washington D.C. 20548: 

Dear Mr. Gootnick, 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO) report on Improvements Needed to Assess 
and Address Growing Migration' from the Compact of Free Association 
(COFA) nations. The State of Hawail generally agrees with the report's 
premises and the Recommendations for Executive Action on page 41, and 
makes the following observations. [Now of p. 43] 

First, the report sets out relative strengths and weaknesses of the 
different enumeration methodologies discussed, but it does not 
highlight the inherent inadequacies of the American Community Survey 
(ACS) for enumeration of small discrete groups such as the COFA 
migrants. [See comment 1] COFA migrants are a small part of the 
general population base, are highly mobile, are not desirous of being 
located or interviewed, and may have weak English language skills. 
Capturing the data for this group requires oversampling and aggressive 
follow up, which the ACS methodology lacks. The report also does not 
point out the obvious discrepancies between the Census estimates in 
each affected jurisdiction compared to the utilization data for 
services provided by agencies in each jurisdiction. In certain cases 
the number actual persons served by an agency can be verified with 
relative confidence, for instance, the number of COFA migrant students 
enrolled in school. A comparison with reported Census data may be 
useful in assessing the accuracy of the different enumeration 
methodologies being proposed. [See comment 2] 

In addition, although the enumeration was established for the sole 
purpose of dividing compact impact assistance among the affected 
jurisdictions, it presents a prime opportunity to gather far more 
valuable information. The use of a methodology that would capture and 
report demographic information about this population would benefit all 
the stakeholders (Department of Interior, the Freely Associated States 
(FAS), and the affected jurisdictions) by providing information and 
the ability to plan and target services and resources to have the 
greatest overall impact, both in the U.S. and the FAS. Some examples 
of useful data may include: information on where migrants are from, 
reported by country of origin (or even by state in the case of the 
Federated States of Micronesia); date of first arrival in the U.S.; 
date of most recent arrival in the U.S.; health needs; age; 
educational attainment; and employment status of residents in a 
household. 

Finally, we would suggest that whatever methodology is selected 
incorporate the interests and utilize the resources of the local 
authorities in each of the affected jurisdictions, which could help to 
eliminate perceived bias, increase participation, and lower the costs 
associated with conducting the enumerations. 

The second recommendation calls for guidelines to be disseminated to 
the affected jurisdictions on how and what to include in the annual 
reports on compact impact. The GAO report indicates correctly that 
there has not been any guidance issued for Hawaii on the substance or 
format of information that should be reported. In addition, there has 
never been any follow-up to the reports that have been submitted prior 
to the investigation conducted for this report. As a result, the State 
has never provided more detailed information about methodology. Newel 
has only attempted to provide essential information on the nature and 
extent of the services provided. The relative detail of the 
information is determined by each agency based on program needs and 
system capabilities. 

We are willing to consider suggested guidelines for reporting data in 
a more detailed and uniform manner, including material such as 
background on the methodology employed by each agency. A standard 
definition of who should be counted would also be very useful. It may 
also be helpful if the Department of Interior worked with officials in 
the affected jurisdictions to formulate standard questions that 
service providers should be asking recipients or applicants for 
services such as date of original entry and most recent entry into the 
U.S.; citizenship of adults in a household; number of U.S. citizen 
children under 18; and number of children under 18 who were born in 
the FAS. 

In addition, we ask the Secretary to recognize that the State's 
resources are already limited and strained. Any reporting requirements 
or guidelines should be necessary, useful, and not create any undue 
burdens on the agencies collecting the data. If there is no further 
review of the reports once they are submitted and they are never 
utilized for any practical purpose, creating bigger and better reports 
would be essentially an exercise in waste and futility. 

Lastly, although we agree with the importance of disseminating 
guidelines for reporting purposes, it is equally important that we 
know If a decision has been made to not distribute guidelines. In this 
scenario, we would then work on guidelines to be distributed among our 
state agencies so that our departmental information would be more 
uniform. However, this process would not start until it was clear that 
the federal government would not be acting in this area. 

The third recommendation calls for the Secretary to work with the 
affected jurisdictions to promote the most effective use of grant 
funds. Hawaii has always utilized Compact Impact assistance for direct 
services to this population, and is confident that this has been done 
in an efficient and cost-effective manner. There have been suggestions 
to distribute the grant funding among many different service providers 
or to create new programs, but that may dilute the effectiveness of 
the funding or create new spending that will be unsustainable in the 
future. However, ideas to increase long-term capacity or efficiency of 
resources, or proposals to build a strong infrastructure of support 
could be of great benefit to the affected jurisdictions, especially if 
these changes would continue to serve the affected jurisdictions 
beyond 2023 when the compact impact funds will no longer be 
distributed. 

The fourth recommendation calls for the consideration of using sector 
grants that would address the needs of Micronesian and Marshallese 
citizens living in the United States. We agree that a portion of the 
sector grants given to the FAS might more effectively be used to 
provide services to Compact citizens living in the affected 
jurisdictions. We would also suggest that the use of the sector 
grants, whether in the FAS or in the affected jurisdictions, should be 
viewed as a continuum across borders and be developed with Input from 
representatives of the affected jurisdictions so that there can be 
increased coordination of the services received by Compact citizens 
wherever they are living. [See comment 3] 

Again, mahalo for the opportunity to comment. If you have any 
questions or need further information, please do not hesitate to get 
in touch with me. A cooperative effort is essential to addressing the 
issues identified in the GAO report. 

Sincerely, 

Signed by: 

[Illegible] for: 
Neil Abercrombie: 
Governor, State of Hawaii: 

The following are GAO's specific comments on the government of 
Hawaii's letter dated October 19, 2011. 

GAO Comments: 

1. The government of Hawaii stated that while the report sets out 
relative strengths and weaknesses of the different enumeration 
methodologies, it does not highlight the inherent inadequacies of the 
American Community Survey (ACS) for enumeration of small discrete 
groups such as compact migrants. Throughout the report we note the 
limitations of the ACS. As our report notes, ACS data have limited 
statistical reliability for populations as small as compact migrants 
in Hawaii. We further note in appendix V that ACS estimates are not 
equivalent to point-in-time estimates and may be biased due to 
nonresponse and coverage error. 

2. The government of Hawaii stated that the report does not point out 
the discrepancies between the Census estimates in each affected 
jurisdiction and the utilization data for services provided by 
agencies in each jurisdiction, such as the number of compact migrant 
students enrolled in school. We did explore the use of school data in 
particular as a basis for evaluating the enumeration findings; 
however, we found that the schools identified compact migrant students 
by language (as in Hawaii) or ethnicity (as in Guam and the CNMI). 
These definitions do not match that contained in the amended compacts' 
enabling legislation and could include the children of persons with 
FAS ethnicity who were present in Hawaii prior to the compacts or the 
children of persons who were born in U.S. areas. For this reason, 
although they are informative in a general way, the difference between 
the school data and the enumeration data could result from 
methodological differences as well as from any potential miscount in 
the enumeration. 

3. The government of Hawaii stated that it agrees that a portion of 
the sector grants given to the FAS might more effectively be used to 
provide services to compact citizens living in the affected 
jurisdictions and that the affected jurisdictions should provide input 
into the uses of the grants. In response to other comments, we 
clarified our recommendation regarding compact sector grants to not 
imply that the use of sector grants to address migration concerns 
should be in the affected jurisdictions. Our recommendation is to 
highlight the nexus between sector grants and the issues that concern 
the FAS, compact migrants and affected jurisdictions. We also report 
that the Federated States of Micronesia has used sector grant funds 
for activities in the affected jurisdiction of Guam. 

[End of section] 

Appendix XI: Comments from the Government of Guam: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

Office of the Governor of Guam: 
Eddie Baza Calvo, Governor: 
Ray Tenorio, Lieutenant Governor: 
Ricardo I. Bordallo Governor's Complex: 
Adelop, Guam 96910: 
Tel: (671) 472-8931/6: 
Fax: (671) 477-4826: 
[hyperlink, http://www.governor.guam.gov] 

October 13, 2011: 

Mr. Emil Friberg: 
Assistant Director, International Affairs and Trade: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Hafa Adai Mr. Friberg: 

Thank you for allowing the Government of Guam the opportunity to 
respond to your draft report entitled "Compacts of Free Association: 
Improvements Needed to Assess and Address Growing Migration". We are 
pleased that the Government Accountability Office (GAO) decided to 
undertake a review of the current state of migration from the Freely 
Associated States (FAS), the enumeration of Compact migrants, 
reporting of the cost of providing education and social services, and 
the actions of the Department of the Interior in relation to Compact 
impact reporting and mitigation. 

Much has changed since the issuance of your prior report "Foreign 
Assistance: Migration from Micronesian Nations Has Had Significant 
Impact on U.S. Island Areas (GAO-02-40)". It was hoped that this 
review of the impacts of the Compacts of Free Association on Guam and 
the other affected jurisdictions would produce definitive guidance on 
measures needed to be taken to mitigate the increased costs as a 
result of the immigration provision of the Compacts. 

The fact that Interior's poor record of producing Compact impact 
reports during the time period of this study and failure to include 
the views of the affected jurisdictions is unacceptable and shows its 
lack of leadership in this area in past years. The costs borne by Guam 
for expenditures on behalf of Compact migrants is an unfunded federal 
mandate resulting from policy actions of the federal government which 
must be reimbursed to Guam. 

During our review, we noticed that the draft report does not address 
in detail how the two options available in the Compact and its 
enabling legislation - direct financial compensation to the affected 
jurisdictions and non-discriminatory limits on migration - could be 
used to address the impacts caused by the migration from the FAS. [See 
comment 1] The draft report does not say under what circumstances the 
current $30 million for Compact impact reimbursement should be raised 
and to what level would be considered fair. There is also no mention 
of the option of debt-relief for previously accrued and un-reimbursed 
cost as was provided for in the Compact law, P.L. 108-188. [See 
comment 2] 

The requirement that each FAS citizen seeking to enter Guam and the 
island areas present a passport or official travel document has helped 
to establish a Compact migrant's entitlement to Compact privileges. 
However, the limits to migration through pre-screening as suggested in 
the Congressional letter of request to the GAO and as now proposed in 
the FY 2012 Defense bill before Congress are not discussed. Pre-
screening will help to insure that Compact migrants meet all 
immigration and other entry requirements. [See comment 3] 

On a positive note, the draft report does mention Congressional 
actions that recently occurred. Congresswoman Madeleine Bordallo has 
introduced a bill that would include Compact migrants under the Impact 
Aid program for education in recognition that they are present based 
on a treaty between the federal government and the Freely Associated 
States. Hawaii's Congressional delegation has introduced bill in the 
House and Senate to restore Medicaid benefits to Compact migrants, 
This is a good start in increasing the eligibility of Compact migrants 
for federal programs which will decrease the costs of providing 
educational and social services to Compact migrants living on Guam and 
the other affect jurisdictions. 

Attached are our complete comments to the draft report. 

Sincerely Yours, 

Signed by: 

Eddie Baza Calvo: 
Governor of Guam: 

Attachment: 

[End of letter] 

Office of the Governor:
Government of Guam: 
P.O. Box 2950
Hagatna, Guam 96932: 

Response to the GAO Draft Report:    

Compacts of Free Association: Improvements Needed to Assess and 
Address Growing Migration: 

GAO-42-64: 

October 2011: 

Compacts of Free Association: 

Improvements Needed to Assess and Address Growing Migration: 

General Comments to Draft Report GAO-12-64: 

1. Federal funds are not included for reimbursement because Interior 
considers reimbursement of federal funds "double-dipping" or getting 
additional federal funds for federal funds expended. According to 
Interior's 1994 guidelines: [See comment 4] 

Guam's impact cost computations incorrectly included amount expended for
Federally funded programs, since the costs of the programs were already
financed by the Federal Government. The inclusion of the same costs in 
the Compact impact calculations represents a duplicative claim for 
Federal reimbursement. 

2. There is no discussion on what costs are legitimate reimbursable 
Compact impact costs. [See comment 5] 

A. What costs are considered legitimate reimbursable costs incurred by 
the affected jurisdictions? 

B. Does Interior recognize these costs as legitimate (why or why not)? 

C. On what basis will the costs be determined for each affected 
jurisdiction (because of different accounting systems in each area)? 

D. How and where do the affected jurisdictions find the data to report? 

E. How is the data to be reported? 

3. It was hoped that this review of the impacts of the Compacts of 
Free Association on Guam and the other affected jurisdictions would 
produce definitive guidance on measures needed determine costs and the 
steps that need to be taken to mitigate these costs as a result of the 
immigration provision of the Compacts. [See comment 6] 

4. The fact that Interior's poor record of producing Compact impact 
reports during the time period of this study and failure to include 
the views of the affected jurisdictions is unacceptable and shows its 
lack of leadership in this area in past years. The costs borne by
Guam for expenditures on behalf of Compact migrants is an unfunded 
federal mandate resulting from policy actions of the federal 
government which must be reimbursed to Guam. 

5. During our review of the draft report, we noticed that the draft 
report does not address how the two options available in the Compact 
and its enabling legislation, direct financial compensation to the 
affected jurisdictions and non-discriminatory limits on migration, 
could be used to address the impacts caused by the migration from the 
FAS. The report does not address the adequacy of the $30 million in 
Compact impact reimbursement provided to the affected jurisdictions as 
requested in the Congressional letter to the GAO under the section 
entitled "Overall adequacy of current Compact-impact assistance". The 
report does not report under what circumstances the amount of Compact 
impact reimbursement should be raised and to what level would be 
considered fair. Also, there is no mention of opportunities the 
federal government may have to reimburse the affected jurisdictions or 
of the option of seeking debt-relief for previously accrued and un-
reimbursed cost as was provided for in the Compact Law as amended, 
P.L. 108-188. [See comment 7] 

6. According to the Congressional letter to the GAO in the section 
titled "Federal interagency cooperation for screening and 
admissibility", a review was requested of interagency, 
intergovernmental and diplomatic cooperation for examining the 
suitability and admission into the United States of FAS citizens in 
accordance with the Compacts of Free Association and applicable 
provisions of the Immigration and Nationality Act. The requirement 
that each  FAS citizen seeking to enter Guam or the other affected 
jurisdictions present a passport or official travel document has 
helped to establish a Compact migrant's entitlement to Compact 
privileges. However, the limits to migration through pre-screening as 
suggested in the Congressional letter of request to the GAO and as now 
proposed in the FY 2012 Defense bill before Congress are not 
discussed. Pre-screening will help to insure that Compact migrants 
meet all immigration and entry requirements. [See comment 8] 

7. On a positive note, the draft report does mention Congressional 
actions that recently occurred. Congresswoman Madeleine Bordallo has 
introduced a bill that would include Compact migrants under the Impact 
Aid program for education in recognition that they are present based 
on a treaty between the federal government and the Freely Associated 
States. Hawaii's Congressional delegation has introduced bill in the 
House and Senate to restore Medicaid benefits to Compact migrants. 
This is a good start in increasing the eligibility of Compact migrants 
for federal programs which will decrease the costs to Guam and the 
other affected jurisdictions. 

8. Another area not addressed in the draft report is the ancillary 
benefits of the enumeration of Compact migrants. No significant socio-
economic data on is available from 2008 Survey of COFA Migrants due to 
the methodology used (short form with few questions). Data quoted in 
the draft report is limited to the data from the 2003 enumeration and 
prior years. Interior's keeping with the letter of the law has done a 
disservice to the affected jurisdictions. Data lost can never be 
regained - point in time means once the moment passed, it's gone. [See 
comment 9] 

9. According to the Congressional letter to the GAO in the section 
titled "Access to Department of Defense (DoD) medical facilities", the 
question was asked about the status of implementing arrangements and 
other protocols between civilian and DoD authorities affecting the 
referral of FAS citizens for medical diagnosis and treatment, how does 
DoD interpreting authority provided by Sec. 104(e)(7)(A), and what is 
the comparison of referral policy affecting FAS citizens between U.S. 
Naval Hospital, Guam and Tripler Army Medical Center, Honolulu, 
Hawaii. This issue is not addressed in the draft report. [See comment 
10] 

10. While the funding for health in the Freely Associated States 
through the sector grants will help in the short term, FAS citizens 
will still migrate for health reasons unless the level of care is 
substantially increased. Similarly, Compact sector funding for 
education would help lessen the need to migrate to receive a better 
education and insure that FAS students who do migrate perform better 
in their new schools in the short term. However, as mentioned in the 
previous GAO report, the migrating to further one's education by 
attending college in Guam and Hawaii will not help the FAS nations 
unless they can provide these highly educated people with jobs and 
wages commensurate with their skills when they return home. 

11. While the concept of using the Compact sector grants to assist 
Compact migrants may lessen the impacts on the affected jurisdictions, 
diverting them from their intended use within the FAS itself must be 
carefully weighted. Socio-economic improvements within the FAS may 
yield more sustainable results and lessen the need for migration. 

12. Interior must make a clear, unambiguous statement on its position 
on Compact impact reimbursement; its recognition of its role to 
mitigate impacts; its recognition of the impacts to the affected 
jurisdictions; its commitment to work with the FAS and affected 
jurisdictions to resolve issues surrounding reasons for migration; 
clearly state its position on criminal deportations and deportations 
in general with regards to family unity; position on the limits to 
migration, in particular, pre-screen as mentioned by the Congressional 
requesters and the FY 2012 Defense bill; and how Interior will protect 
the rights of Compact migrants in light of recent toughening of state 
laws targeting undocumented immigrants. 

13. Guam does recognize Compact migrants' contribution to the overall 
economy of the island. However, federal policy such as the earned 
income tax credit (EITC), Medicaid caps, limited access to certain 
federal health and social service programs, etc., are negating any 
benefits. 

14. The terms "agency" and "agencies" are used to refer to the sources 
of Compact impact annual reports in the affected jurisdictions or the 
affected jurisdictions directly. However, the term is also used to 
describe the individual entities that provide these "agencies" with 
the information for the Compact impact reports. It is sometimes 
difficult to identify who the draft report is referring to when 
reading a particular sentence. In many cases, the entire section must 
be read to give the proper context. [See comment 11] 

[Pages in the draft report may diffe3r from those in this report] 

Draft Page 8: 

Foot note 15 - Census was not told by Interior about children under 18 
year for the 2008 Survey of COFA Migrants. Guam informed Census who 
later verified it with Interior. 

Draft Page 11: 

1. Interior should fund a special tabulation by the Census Bureau 
based on the 2010 Census of Guam. 

A. It should include status of US-born and Guam-born children of Compact
migrants. 

B. Prior Micronesian censuses have done cross-tabulations of small 
populations. 

2. There have been five Micronesian Censuses on Guam since 1986. The 
1995 Census of Palauans is missing. 

A. 1992 Census of Micronesians on Guam (FSM and RMI only). 

B. 1995 Census of Palauans. 

C. 1997 Census of Micronesian Migrants to Guam. 

D. 2003 Census of Micronesian Migrants to Guam. 

E. 2008 Survey of COFA Migrants. 

3. Only the latter three censuses/surveys covered all Compact migrants. 
[See comment 12] 

Draft Page 16: 

Based on the recently released 2010 Census population of Guam (159,358 
persons), the percentage of Compact migrants on Guam is 11.6% based 
2008 population estimate of 158,437 persons [hyperlink, 
http://2010.census.govinews/releases/operations/cb11-en179.html]. 
[See comment 13] 

Draft Page 18: 

1. The block sampling was done based on 2000 Census block data which 
had a high Compact migrant population as the starting point. This was 
supposed to be updated with 2008 information of Compact migrant 
concentrations. There should be a statement about the source of the 
2008 information and how it was applied to the 2000 blocks to 
determine the new Compact migrant concentrations for the 2008 Survey 
of COFA Migrants. 

2. The 1995 Palauan survey should be included in footnote 18. [See 
comment 9] 

3. The 2008 Survey of COFA Migrants basically followed the letter of 
the law, not the spirit of the law which is to assess the status of 
Compact migrants. 

4. The terms "census" and "survey" are used interchangeably when 
referring to Compact migrant counts. All are in fact surveys since 
they are not complete enumeration of all persons. To count homeless 
persons would mean a full Census of a subset of a sub-population. [See 
comment 14] 

Draft Page 19: 

Change footnote to read "... that allowed the construction of 
additional tables ..." 

Draft Page 20: 

If Interior and/or Census had asked OMB to consider the snowball 
method, the question of fairness between the affected jurisdictions 
may have been avoided. Also, this could have led to a survey 
instrument that collected the socio-economic data which the affected 
jurisdictions were seeking. 

Draft Page 27 (also applies to Draft Page 66): 

1. Definition of compact migrants: 
The draft report questions the use of ethnicity, language, citizenship 
and other proxies rather than the definition according to the compacts 
enabling legislation. Yet, nowhere is here an explanation of what 
should be basis of identifying Compact migrants or how it should be 
accomplished. [See comment 15] 

2. Federal funding: 

A. It is unclear what reasoning behind the concept of federal funding 
offsets and how they are applied. Guam reports are based on locally 
funded costs only. Compact migrants would use a certain percentage of 
federal hinds as indicated in the report, but that amount is 
ineligible for further reimbursement ("displacement cost"). There is 
no clear reason given as to why this amount should be subtracted from 
the local cost amounts as a credit since these are two separate 
funding sources. 

B. In a formula grant based on population, the number of Compact 
migrants living on Guam do not significantly increase the amount of 
federal funds Guam would otherwise be eligible to receive without 
their inclusion. Moreover, in many population-based formula grant 
programs, the addition of their population has no impact upon the 
amount of federal funds Guam would otherwise be entitled to receive 
because there is a minimum level set for all recipients. 

C. Considering all population-based federal funds as containing 
offsets of Compact impact costs assumes that these costs for services 
rendered proportionately based on the percent of Compact migrants or 
their use of a service. The federal funds expended for Compact 
migrants in excess of their proportionate share are funds that would 
have otherwise been available for the benefit of a local client. This 
would be part of what would be referred to as "displacement cost" to 
Guam for which reimbursement can not be included in Compact impact 
cost calculations as they are considered a duplicative claim for 
Federal reimbursement according to Interior. 

D. Extending the argument, this would mean that population-based 
federal funds for which Compact migrants use less than their 
proportionate share would generate a "credit" according to the 
example. This would mean that costs in excess of their proportionate 
share would be eligible for reimbursement, possibly being offset by 
this "credit". 

E. If Compact migrants are ineligible or otherwise derived no benefit 
from population-based federal funds, the application of a "credit" 
raises would seem to raise some ethical questions. 

F. Literature citations describing the rational of these adjustments 
and examples of the application this methodology in immigration 
research is needed. 

3. Capital costs: 

A. Leaseback program for new schools: 
1. The schools were built with federal dollars (Compact impact funds). 

2. This would make it ineligible for reimbursement as an education
capital cost. 

B. There has been no specific guidance from Interior on what capital 
costs can be considered for reimbursement and how to capture the 
information. 

Draft Page 28 (also applies to Draft Page 68): 

There is a general description of the methodology used for each 
reporting agency. Although the methodology may not be used by the 
individual reporting agencies, the Bureau of Statistics and Plans 
follows the methodology stated and policy directives given to the 
Bureau. 

Draft Page 29 (also applies to Draft Page 68): 

The first paragraph should read as follows to more accurately reflect 
the situation: 

"... told us that the bureau attempts to adhere to them when preparing 
compact impact cost estimates. The bureau does not provide these 
guidelines in its annual letter to the agencies when requesting 
compact impact costs since the agencies do not do their reports for 
Interior directly. The bureau applies the guidelines to the data from 
by the agencies in the annual report submitted to Interior." [See 
comment 17] 

Draft Page 30: 

1. Interior's insistence on the inclusion of the economic 
contributions of Compact migrants has been a standard line since the 
1980's. However, no assistance or guidance has ever been offered. 

2. Although Interior says it will do so, timely submission does not 
equate to completeness as this report points out. 

3. No socio-economic data on Compact migrants is available for 2008 
Survey o f COFA Migrants due to the methodology used (short form with 
few questions). Interior's keeping with the letter of the law has done 
a disservice to the affected jurisdictions. [See comment 9] 

4. Cost-benefit analysis: 

A. This would seem reasonable if the Compacts were for recruiting 
labor. However, the concept of a cost-benefit analysis for Compact 
migrants would seem inappropriate given their special status. The 
Compacts gave Compact migrants the right to seek employment in a 
similar fashion as any US citizen, green card holder, or other work-
eligible person. 

B. Without the application of the immigration visa requirements, 
Compact migrants are not really immigrants, migrants, or non-immigrant 
aliens but persons seeking opportunities under the American economic 
and social system like any other US citizen. They are free to 
establish residence in any state, territory, or possession. 

C. Compact migrants have rights that other non-immigrants as well as 
immigrants do not possess; they are not subject to controls like H-2B 
workers who face restrictions on when and where they work that affect 
their income potential. 

D. When discussing cost of social services to US citizens, there is 
never a discussion of the economic contribution they provide being 
subtracted out when reporting the cost of the services provided. Also, 
the Compacts do not ask about benefits. [See comment 18] 

Draft Page 32: [See comment 19] 

1. There is no mention of Elizabeth Greico's "The Remittance Behavior 
of Immigrant Households: Micronesians in Hawaii and Guam" (also Draft 
Page 48) as a comparative source. 

2. The source report stating the basis of the Manuel Orozco 
calculation that Compact migrants sent back as much as $71 million 
home should be cited. 

3. No data on consumption and remittances were collected in 2003 
because Interior limited the scope of the survey: 

However, at the request of the Office of Insular Affairs, Department 
of the Interior, we developed the 2003 surveys to measure only 
negative impact; hence, we collected little housing data and no 
expenditures data, so we will not update those chapters in this 
report. ("The Status of Micronesian Migrants in 2003", Page 11) 
 
4. This means that Interior does recognize that the Compact language 
only asks about costs of providing educational and social services and 
does not ask about benefits to the affected jurisdictions. Otherwise, 
they would have insured that housing and expenditure data be collected. 

Draft Page 34: 

It should be noted that, prior to 2004, Guam could only use the 
Compact Impact grants for capital improvement (CIP) projects. 

Draft Page 40: 

1. The guidelines from Interior to the affected jurisdictions must be 
uniform across all jurisdictions. The cost basis must be the same 
(inclusions and exclusion). [See comment 20] 

2. Interior must respect the affected jurisdictions' right to 
determine what is appropriate for the jurisdiction to expend its 
Compact impact funds as currently being done. 

Draft Page 41: 

1. We agree in principle to the four recommendations for executive 
actions by Interior as recommended by the GAO. 

2. Because each jurisdiction has its own method of funding various 
social services which has led to the incomparability of between the 
areas, we recommend more that just general guidelines. The guidelines 
must specifically state what is to be collected, source of the data, 
caveats, etc. as well as how it is to be reported for each affected 
jurisdiction given that each reporting system will be different. [See 
comment 21] 

3. Alternate uses of Compact impact grants must balance the need and 
public good while provide more directed assistance to Compact migrants. 

Draft Page 48: 

Change to read "... their average wages, and taxes paid. The method 
..." 

Change to read "... first outlined by an official in the" 

Draft Page 52: 

1. Change to read "... affected jurisdictions because Arkansas does 
not ..." 

2. The issues facing Arkansas when asked to provide education and 
social services data on the Marshallese are similar to that faced by 
Guam when Compact Impact reporting began. For example, as with 
Arkansas education data, the information collected about the students 
were aggregated into a general category or not collected at the 
necessary specificity. Baseline data would have to be estimates based 
on available data (Interior seems to have a problem this concept). 

Draft Page 54: 

Arkansas differs from the affected jurisdictions in terms of the labor 
market and recruitment. There has been active recruitment of 
Marshallese citizens by local Arkansas businesses to the extent we do 
not believe happens on Guam. 

Draft Page 57: 

The second sentence of footnote 52 - "As of September 2011, ..." - 
should be moved to the end of the first paragraph. Alternately, a 
third section should be added to discuss the 2010 Census for Guam and 
the Commonwealth of the Northern Mariana Islands and the data from
the Census (or lack thereof). Although the data the GAO received was 
only for the Marshallese, the title of Appendix IV is the "2010 
Decennial Census Data on Micronesians by Race". [See comment 22] 

Draft Page 59: 

There should be a section header "Survey design" below the 2003 and 
2008 as all the other sections have headers. 

Draft Page 65: 

Guam believes that the definition of Compact migrant should be defined 
more liberally. 

Draft Page 66: 

1. The comments made for Draft Pages 26 to 29 in relation to Draft 
Pages 65 to 68 should be applied. 

2. Change footnote 92 to read "... The Guam Bureau of Statistics and 
Plans ..." 

Draft Page 68: 

1. Based on the terms of entry in the Compacts, it would seem that 
Compact migrants are "pseudo-citizens", having the ability to access 
all federal and local social services programs unless specifically 
barred. As such, even if the services are discretionary, they are 
provided on a non-discriminatory basis as applied to US citizens. 
Because they are non-immigrant, non-visaed, work eligible non-citizens 
here by federal statute, Compact impact reimbursement is justified for 
all services rendered. [See comment 23] 

2. All affected jurisdictions have had the right to submit Compact 
impact reports since the time of the original Compacts in 1986. The 
only thing that has change is the responsible reporting party which 
was changed from Interior to the affected jurisdictions by P.L. 106-
504. 

The following are GAO's responses to specific comments in the 
government of Guam's letter dated October 13, 2011. 

GAO Comments: 

1. The government of Guam stated that the draft report did not address 
in detail how the two options available in the compact and its 
enabling legislation--direct financial compensation to the affected 
jurisdictions and nondiscriminatory limits on migration--could be used 
to address compact impact. Our report noted that additional 
appropriations are authorized in the amended compacts' enabling 
legislation; however, no additional appropriations have been provided 
to date and remain an option for Congress. We do not address limits on 
migration in our report. 

2. The government of Guam stated that our report does not mention the 
option of debt relief for previously accrued and unreimbursed costs as 
was provided for in the amended compacts' enabling legislation. We 
have added a note to the report to describe this provision, but also 
note that the provision expired on February 28, 2005. 

3. The government of Guam stated that the limits to migration through 
prescreening as suggested in the congressional letter of request to 
GAO and as now proposed, according to the government of Guam, in the 
"fiscal year 2012 Defense bill before Congress" are not discussed. We 
do not address limits on migration in our report. 

4. The government of Guam stated that federal funds are not included 
in its compact impact reporting. We recognize the Guam Bureau of 
Statistics and Plans attempts to adhere to Interior's 1994 guidelines 
instructing the exclusion of federal funding in compact impact 
reports; however, we found that the bureau and some local government 
agencies do not always follow the guidelines. For example, the Guam 
Bureau of Primary Care Services within the Division of Public Health 
and Division of Public Welfare have included federal funds in their 
costs that the Bureau of Statistics and Plans has included in its 
compact impact reports submitted to Interior. 

5. The government of Guam stated that our report does not discuss what 
compact impact costs are "legitimately reimbursable." In our report, 
we discuss some basic principles regarding adequate cost estimation 
that we derived from OMB and our own guidance to identify the 
characteristics of costs that are accurate, well-documented, and 
comprehensive. However, Interior's implementation of our 
recommendation to disseminate adequate guidelines may further instruct 
affected jurisdictions as to which costs are legitimate. 

6. The government of Guam stated that it hoped our report would 
produce definitive guidance on measures needed to determine compact 
impact and the steps that need to be taken to mitigate these costs. We 
believe that our recommendation that Interior prepare adequate cost 
guidance will help in determining compact impact costs. 

7. The government of Guam stated that our report does not address how 
financial compensation to affected jurisdictions, limits on migration, 
or debt relief could address impacts. See our response in comments 1, 
2, and 3. 

8. See our response to comment 3. 

9. The government of Guam stated that the 2008 Census survey has done 
a disservice to the affected jurisdictions because it did not collect 
additional data. As our report notes, the lack of this data is one of 
the limitations of the 2008 and potentially the 2013 approach. 

10. The government of Guam stated that our report does not address the 
amended compacts' enabling legislation's provisions for access to 
Department of Defense medical facilities by citizens of the FSM and 
Marshall Islands. We have added a note in the report to document that 
such access exists, but we have not addressed the referral policies of 
Department of Defense facilities in Guam and Hawaii. 

11. The government of Guam requested we clarify the sources of compact 
impact reporting when we refer to "agency" and "agencies" in our draft 
report. We made changes throughout our report to more specifically 
identify the agencies. 

12. The government of Guam noted that the 1995 Census of Palauans was 
not included in our report. We have now added a note with the findings 
of this survey. As Guam noted, unlike other surveys we have included 
in the report, this survey did not cover all three FAS. 

13. The government of Guam stated that the recently released 2010 
decennial census affects the estimate of 2008 Guam population used in 
figure 4. We have updated the estimated populations of affected 
jurisdictions used for figure 4 to use an estimate interpolated from 
2000 and 2010 Census data. Like Guam, we now estimate that migrants in 
2008 were approximately 11.6 percent of Guam's population. 

14. The government of Guam noted that the terms "census" and "survey" 
are used interchangeably when referring to compact migrant counts but 
all counts are in fact surveys and omit the homeless. We have reviewed 
the text for our use of the terms "census" and "survey" and have also 
added a discussion of the various Census surveys' approaches to 
counting the homeless population in appendix V. 

15. The government of Guam stated that the report draft questioned 
affected jurisdictions' varying definitions of compact migrants, which 
are based on proxies rather than what is stated in the amended 
compacts' enabling legislation, but did not provide an explanation of 
the correct definition. In our draft report we included the definition 
of the amended compacts' enabling legislation in appendix VI but have 
now also added it to the main body of the report. 

16. The government of Guam stated that it is unclear about the 
application of federal funding offsets in its impact reporting, which 
it refers to as displacement costs, and asserted that its reports are 
based on locally funded costs only. Guam also noted that in population-
based formula grants the number of compact migrants does not 
significantly change the amount of funds available to Guam. The 
government of Guam said that any spending over this type of federal 
funding is considered a displacement cost because it would have 
otherwise been available to a local client. We believe that our 
recommendation that Interior prepare adequate cost guidance will help 
in determining compact impact costs. 

17. The government of Guam stated it would like the report to replace 
a paragraph to reflect how the Bureau of Statistics and Plans handles 
guidelines regarding compact impact reporting. The government of Guam 
said it does not provide Interior's guidelines to the reporting local 
government agencies, but attempts to apply them when compiling the 
data it receives in preparation for submission to Interior. We updated 
our paragraph with the additional information but also noted that we 
found some cases where the bureau and local Guam agencies did not 
follow Interior's guidelines. 

18. The government of Guam stated that when discussing the cost of 
social services to U.S. citizens, the compacts do not discuss the 
subtraction of economic contributions when calculating the cost of 
services provided, and do not mention the inclusion of compact 
benefits. The amended compacts' enabling legislation does not require 
the inclusion of such data in affected jurisdictions' impact reports 
and complete data on compact migrants' contribution to local economies 
does not exist. We provided available information on labor market 
participation, taxes, consumption, and remittances. 

19. The government of Guam asked that we cite a study by Elizabeth 
Grieco as a comparative source on remittances and a source for the 
estimates of Mr. Orozco. Ms. Grieco's study uses the same 2003 Census 
data we cite in our report, but we have added it as a citation. We 
have also added an additional citation to the methodology used by Mr. 
Orozco. 

20. The government of Guam stated the guidelines from Interior 
regarding compact impact reporting must be uniform across all 
jurisdictions and that it must respect the affected jurisdictions' 
right to determine what is appropriate for the jurisdiction to expend 
to address compact impact. However, there are opportunities to more 
effectively use those funds. These opportunities may help address some 
of the needs identified by various officials, service providers, and 
compact migrants. These needs include access to language and cultural 
assistance, job training, and improved access to basic services for 
compact migrants. These sources suggested that migrant needs could be 
addressed by, for example, establishing centers that offer such 
services. 

21. The government of Guam stated that it agrees in principle with our 
four recommendations. It also noted that guidelines must specifically 
state what data is to be collected and how. We agree that having clear 
and detailed guidelines would help affected jurisdictions when 
developing their impact reporting. With regard to usage of compact 
funding, please see our comment in response 20. 

22. The government of Guam suggested edits to the text of appendix IV. 
We have moved the sentence on the availability of Guam and CNMI 
estimates to the text as they suggest. We have not changed the title 
of the appendix because it addresses data for all three FAS, though 
only data on Marshallese are currently available. 

23. In response to the discretionary costs discussion in our draft 
report, the government of Guam stated that, based on the terms of the 
compacts, it seems compact migrants are treated as if they are 
citizens in that they have access to all federal and local services 
unless specifically barred; therefore, reimbursement is justified for 
all services rendered because they are provided on a nondiscriminatory 
basis. We believe that our recommendation that Interior prepare 
adequate cost guidance will help in determining compact impact costs. 

[End of section] 

Appendix XII: Comments from the Government of the Commonwealth of the 
Northern Mariana Islands: 

Commonwealth Of The Northern Mariana Islands: 
Benigno R. Fitial, Governor:  
Eloy S. Lam, Lt. Governor: 
Caller Box 10007: 
Saipan, MP 96950: 
Telephone: (670) 664-2200/2201: 
Facsimile: (670) 664-2211: 

October 12, 2011: 

David B. Gootnick: 
Director: 
International Affairs & Trade: 
U.S. Government Accountability Office: 
Washington, DC: 

Dear Mr. Gootnick: 

Thank you for the opportunity to comment on the GAO-12-64 report, 
"Improvements Needed to Assess and Address Growing Migration". 

Regional cooperation as in the Micronesian Chief Executive Summit 
brings leaders of the Micronesian islands together to discuss 
important issues affecting the region. One such issue is the impact 
and contributions of the FAS migrants in Guam, Hawaii and CNMI. We 
want to state that we welcome all FAS migrants to live and contribute 
to the economy and the communities in the CNMI most especially during 
this time of federal transition. It is important to note that regional 
collaboration and partnership play an important role in the 
development of our economic future. 

For the past few years, CNMI had voiced concerns over the 
disproportion in compact impact grant reimbursements. What the CNM1 
claims are not commensurate to what the US Congress allocates, and
the amount DOI/0IA reimburses. This report points to weaknesses in the 
CNMI's reporting methodology due to DOI/0M's inadequate guidelines of 
1994 and limitations in enumeration approaches as possible reasons why 
such gaps occur. We seek to address these issues with DOI/OIA based on 
recommendations provided by the report. 

We generally agree with the report's recommendations and further 
recommend that DOI/OIA consult with the CNMI on developing future 
guidelines using resources and recommendations from the DOI/OIG report 
of 1993,[Footnote 1] OMB circular A-94,[Footnote 2] GAO-09-3SP, 
[Footnote 3] and GAO-04-733.[Footnote 4] We also recommend that 
DOI/OIA consult with the CNMI on the best approach to enumerate all 
compact migrants, quantify migrants' economic contributions and 
effects in the CNMI, and other purposes. 

Finally, we further recommend that the US Congress with CNMI's 
Delegate to the US Congress, without delay, provide additional 
appropriations as mandated by the 2003 Amended Compact legislation to 
redress the outstanding costs for services provided to FAS migrants 
from past years to present. 

We anticipate working with DOI/OIA and the FAS countries to address 
these issues cooperatively. 

Sincerely, 

Signed by: 

Benigno R. Fitial: 

Appendix XII Footnotes: 

[1] Department of Interior Office of the Inspector General, Audit 
Report: Impact of the Compact of Free Association on the Government of 
Guam, Report No 93-1-1195 (1993). 

[2] OMB Circular No. A-94, Guidelines and Discount Rates for Benefit-
Cost Analysis of Federal Programs, revised October 29, 1992. 

[3] GAO-09-3SP, Cast Estimating and Assessment Guide: Best Practices 
for Developing and Managing Capital Program Costs. 

[4] GAO-04-733, Illegal Alien Schoolchildren: Issues in Estimating 
State-by-State Costs. 

[End of section] 

Appendix XIII: Comments from the Government of Arkansas: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

Arkansas Department of Health: 
4815 West Markham Street: 
Little Rock, Arkansas 72205-3867: 
Telephone (501) 661-2000: 
Governor Mike Beebe: 
Paul K. Halverson, DrPH, FACHE, Director and State Health Officer: 

October 11, 2011: 

Dr. David Gootnick: 
Director, International Affairs and Trade: 
U.S. Government Accountability Office: 
441 G. St., NW: 
Washington, DC 20548: 

Dear Dr. Gootnick, 

This is in response to your request that staff in Arkansas review the 
draft report entitled "Compacts of Free Association: Improvements 
Needed to Assess and Address Growing Migration." Our view of this 
document is set out below. 

1. The history and scope of the migrant issue is reviewed adequately. 

2. The lengthy discussion regarding how best to enumerate the migrants 
in a state or territory is well done. It is clear that few persons are 
satisfied that the correct numbers are in hand and that the variations 
among the states are probably greater than the data reflect. 

3. As a general statement we agree that Arkansas has a large number of 
migrants from the Marshall Islands, certainly the largest number in 
the continental U.S. 

4. The methods used to determine government expenditures for the 
Marshal Islanders are an estimate at best because many health services 
provided could not be determined since ethnicity is frequently not 
recorded on health records at the Arkansas Department of Health or in 
other health provider institutions. 

5. We have no objective basis to disagree with the data you give for 
Arkansas since these are the data we provided to you. However, we are 
in serious doubt about the count of the migrants thinking that there 
is an undercount despite the good efforts of those charged with the 
counting operation. In particular we are concerned about figure 2 on 
page 14. [See comment 1] It shows the number of migrants in each of 
several states as determined by the American Community Survey (ACS) 
that relies heavily on mail survey methods sent to selected 
households. The number of migrants in Arkansas as shown in the figure 
is 1,155 total for the period of 2005-2009. This is a very serious and 
misleading undercount, indeed there were 1,092 Marshallese children in 
grades K-12 enrolled in the Springdale school system in the year
2008-2009. Later on in the report on page 57 of the appendix the 2010 
census count for Marshallese in Arkansas is given as 4,324 as set out 
in table 6. [Now on p. 63] 

We ask that Figure 2 be reconfigured to show the values for the 2010 
census rather than the data from the flawed ACS report. This is most 
important because Figure 2 as it stands is a powerful visual that will 
impress readers of your report in contrast to the table hidden away on 
page 57 of the appendix. We are very concerned that congressional 
leaders and staff who review the GAO report will be much more likely 
to see and remember Figure 2 as it stands instead of the more accurate 
data shown in the appendix. Specifically we ask that 2010 census data 
be used to create Figure 2 rather that the ACS data. 

6. We recognize that it is stated more than once within the report 
that the affected jurisdictions have expressed concern that they do 
not receive adequate compensation for the costs of providing 
government services to the migrants. In the case of Arkansas it should 
be made clear that Arkansas has never received any compensation as 
reimbursement for the services provided over the years. 

Thanks to you and your staff for your work to inform congressional 
leaders about the compact and its impact on the various states and 
territories. 

Sincerely, 

Signed by: 

Joseph H. Bates, MD, MS: 
Deputy State Health Officer: 
Chief Science Officer: 

The following is GAO's comment on the Arkansas Department of Health's 
letter dated October 11, 2011. 

GAO Comments: 

1.The Arkansas Department of Health expressed serious doubts about the 
count of Arkansas migrants based on American Community Survey data and 
asked that 2010 census data be used to create figure 2 rather than the 
ACS data. We agree that there are differences between the count based 
on the ACS data and that based on 2010 decennial census data and have 
listed some of the reasons for the differences in appendix IV. We have 
added text to the report to more explicitly describe this appendix, 
the differences between the data sets, and Arkansas's concerns. 

[End of section] 

Appendix XIV: Comments from the Government of the Federated States of 
Micronesia: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

Embassy Of The Federated States Of Micronesia: 
1725 N Street NW: 
Washington, D.C. 20036: 
Telephone (202) 223-4383: 
Telefax: (202) 2234391: 
[hyperlink, http://www.fsmembassydc.org] 

12 October 2011: 

David B Gootnick, PhD: 
Director: 
International Affairs & Trade: 
US Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Dr Gootnick: 

The Government of the Federated States of Micronesia (FSM) expresses 
its sincere appreciation to the US Government Accountability Office 
for extending the invitation to comment on the draft report: "Compacts 
of Free Association - Improvements Needed to Assess and Address Growing
Migration." While the exercise is entirely an initiative of the US 
Government, we acknowledge its necessity as a tool in discerning and 
generating areas of possible improvement in our bilateral relationship 
pursuant to the Compact, as amended. Just as well, we recognize the 
hard work, diligence and professionalism that the GAO brought to bear 
on a multifaceted, complex and increasingly important subject, namely, 
the "impact" of the migrant populations of the Freely Associated 
States on the communities in which they reside in the US, particularly 
in the "affected jurisdictions" as defined by the Compact treaty. 

Surely "Compact Impact" has taken on a new significance, and the 
migration of the FAS citizens to the US, including its territories and 
possessions, appears to be the leading contributor to placing the 
subject on the radar screen. It is precisely for this reason that we 
have been looking forward to the GAO report, as it is our sincere 
desire to help addressing the Compact Impact resulting from the 
migration of our citizens to the US and to also seek ways of improving 
their welfare. 

Without meaning to delve into history, the "habitual residence" 
provisions of the Compact are one element that gives the treaty its 
unique character and practical meaning - a tribute to the architects 
of the treaty on both sides who envisioned the Compact as not just a 
mere relationship but a special and profound partnership. Thus, it is 
our desire in collaboratively addressing the Compact migrant impact 
issue to ensure that the treaty continues to be mutually beneficial to 
both the US and the FSM and that the spirit of partnership remains 
intact as the cornerstone and beacon light of the relationship as a 
whole. 

True, in the economic condition of the present, these are real hard 
times for both the FSM and the US. However, the need to approach the 
issue objectively and on factual basis in a collaborative manner 
should not be compromised. 

All in all, the FSM Government has concerns on various parts of the 
draft GAO report. Amongst those concerns, we would like to highlight 
the following: 

1) Inconclusiveness of Findings and Absence of Net Cost and Net 
Contribution: 

We concur fully with the underlying assumption of the GAO study, and 
of those who commissioned it, that hardcore "numbers" or data are 
critical to gaining a fairly accurate picture of the impact of the FAS 
migrant populations in the US. To be credible, any measure aimed at 
addressing the adverse impacts of the "habitual residence" provisions 
of the amended Compact must be based on solid data. It is also highly 
desirable to present a comprehensive picture of the situation, showing 
both the net costs of services extended to the FAS migrants on the one 
hand and, on the other, the wide range of the migrants' contributions 
to the communities where they reside. 

The inconclusiveness of the findings of the GAO report is thus one of 
our main concerns. Our reading is that, despite its hard work and due 
diligence, the GAO is simply not in a position to provide a 
comprehensive picture as to the overall cost of the medical, 
educational, and other social services extended to the Compact 
migrants and the net contributions that they make to their 
communities. In other words, based on the GAO study, it cannot be said 
with maximum certainty that the FSM migrant population are a positive 
contributions to their respective communities; nor can it be said with 
full confidence that the Compact migrants are, on the whole, "free 
riders" on the social service systems of the communities where they 
reside. The statistics, the GAO report tells us, are simply not 
available or are not adequate. [See comment 1] 

But the inadequacy of solid data is not a good justification not to 
collaboratively confront the issue. It is for this reason that we take 
note of the GAO's identification of measures that are necessary to 
facilitate or provide objective bases of addressing the issue of 
Compact migration in the affected jurisdictions. We are indeed pinning 
high hopes on the recommendations outlined in the report. 

2) Impact of Application of Different Measurements: 

We appreciate the GAO draft report's treatment of the different 
approaches that the US Government applied in trying to show the 
"picture" of our migrant populations in terms of both impact and 
characteristics. Our concern is that the application of these 
different approaches in different affected areas at different times 
yields numbers that cannot be easily used, if at all, for comparative 
purposes. The numbers as derived from the different approaches are 
less useful, if not misleading, in presenting an accurate picture of 
the scope of the Compact migration impact. 

We are just as concerned that this "impact" of past disagreement in 
the selection of approaches to use may continue when the 2013 census 
is carried out. It is our hope — request rather -- that those who are 
parties to, or will be involved in, the conduct of the census in 2013 
hammer out an agreement on the best approach. 

3) Inconsistency in the Definition of Compact "Migrant:" 

The question as to what constitutes a "Compact migrant" is critical to 
gaining a clear and accurate picture and scope of the migrant impact 
issue It is very important that "Compact migrant" be clearly defined, 
or we will run the risks of miscounting the numbers and inaccurately 
describing the impact. One particular area of concern is with the FSM 
citizens who had arrived in the US prior to the entry into force of 
the Compact and who might be counted as "Compact migrants" but who 
should not be. [See comment 2] 

Another concern is with those who were born in the US, hence acquiring 
US citizenship as well, might be counted as "Compact migrants" for 
purpose of adding up the costs of medical, educational, and other 
social services and, on the other hand, listed as "US citizens" where 
their contributions would not be counted. As earlier noted, this 
ambiguity, if not inconsistency, in the definition of a Compact 
migrant is apt to yield not only inaccurate head-count of Compact 
migrants but misleading calculation or estimation of cost of services. 

4) Exclusion of Citizens in the US Armed Forces: 

The security and defense agreement between the FSM and US is another 
significant element of the Compact relationship that we believe is not 
only mutually beneficial but which has brought hundreds of FSM 
citizens to the United States or to serve in the Armed Services of the 
United States. We believe that our citizens in the US military 
constitute a significant portion of our Compact migrant population. 

To present the "whole picture" of the FSM migrant population in the 
US, we insist that our citizens in the US military be included in the 
head count and the calculation of their contributions. Their exclusion 
from the count, we believe, would not tell the whole story. [See 
comment 3] 

5) Medicaid Deductions and Ineligibility for Benefits: 

Our understanding from the draft report is that the costs of providing 
healthcare constitute the second largest expenditures for the affected 
jurisdictions on the FSM "migrant" population. To provide a solid 
basis of addressing this particular issue, it is to be wondered 
whether the aggregate amount of expenditures by the affected 
jurisdictions includes costs for those who came to the US before the 
implementation of the Compact and those who were born in the US after 
the entry into force of the treaty, hence are US citizens as well. 

We also note with particular concern the finding that the FSM citizens 
working in the US pay into the Medicaid program, yet they do not 
receive benefits. This is an area of significant concern because it 
appears to raise an issue of fairness, if not indeed a legal question. 
[See comment 4] 

6) Possibility of Multiple-Counting in Expenditures: 

Subject to correction, it is our understanding that the affected areas 
receive certain federal funding for health, low-income housing and 
other social services -- in addition to the $30 million that is 
appropriated annually for the Compact Impact Fund. What is not clear 
to us is whether the cumulative amount that each of the affected 
jurisdictions claims to spend on the FSM migrants includes payments 
from local sources of funding, the Compact Impact Fund, and federal 
funding. 

It would seem reasonable and appropriate that the sources of payment 
for the cost of extending medical, school, and other social services 
for the FSM migrants be clearly delineated. The interest here is to 
avoid the possibility of multiple-counting of expenditures. 

In closing, we would like to reiterate our gratitude for the 
opportunity to provide our concerns regarding the draft GAO report. We 
do so in the sincerest desire to work collaboratively to address the
Compact migrant issue and, in the end, to sustain the mutual benefits 
of the Compact and its spirit of partnership. 

Respectfully submitted, 

Signed by: 

James A. Naith: 
Charge d'Affaires, and interim: 
(Deputy Chief of Mission): 

The following are GAO's comments on the Federated States of Micronesia 
government's letter dated October 12, 2011. 

GAO Comments: 

1. The government of the FSM stated that our findings on compact 
migrant participation in local economies are not conclusive as to the 
net impact of migrants. The amended compacts' enabling legislation 
does not require the inclusion of such data in affected jurisdictions' 
impact reports and complete data on compact migrants' contribution to 
local economies does not exist. We provided available information on 
labor market participation, taxes, consumption, and remittances. 

2. The government of the FSM stated the importance of clearly defining 
a compact migrant for the purposes of enumeration and reporting 
compact impact. As our report notes, Interior interprets the 
legislation's definition of a qualified nonimmigrant--which generally 
refers to a compact migrant living in an affected jurisdiction--as 
including those migrants' children under the age of 18 who are born in 
the United States; therefore, some U.S. citizens are included in the 
count of migrants. We have used Interior's definition for our 
estimates of compact migrants and costs. As our report also notes, a 
number of reporting local government agencies in affected 
jurisdictions do not use the definition of compact migrants in the 
amended compacts' enabling legislation, which affects the reliability 
of their reported compact impact costs. 

3. The government of the FSM cited the fact that its citizens are 
eligible to serve, and have served, in the armed forces and asked that 
we include them in the count of migrants. We have obtained data from 
the Department of Defense on persons born in the FAS who are on active 
duty in the U.S. armed forces and have added this to the report. 

4. The government of the FSM referred to a statement in the draft 
report that migrants pay into the Medicaid program but do not receive 
benefits. This statement was in error and has been deleted from the 
report. 

[End of section] 

Appendix XV: Comments from the Government of the Republic of the 
Marshall Islands: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

EMBASSY OF THE REPUBLIC OF THE MARSHALL ISLANDS: 
2433 Massachusetts Avenue, N.W. 
Washington, D.C. 20008: 
Tel. (202) 234-5414: 
Fax # (202) 232-3236: 
E-mail: info@rmicmbassyus.org: 

October 14, 2011: 

Mr. David B. Gootnick, Ph. D. 
Director, International Affairs & Trade:  
441 G Street, NW: 
Washington, D.C. 20548:  

Dear Dr. Gootnick,  

I am pleased to transmit the Government of the Republic of the 
Marshall Islands (RMI) comments to the United States Government 
Accountability Office (GAO) report titled "Improvements Needed to 
Assess and Address Growing Migration."  

The comments produced by the RM1 are divided into two sections, 
namely, Technical Comments and Political and Policy Issues with 
respect to the information provided in the report.  

Should you require further explanation, please do not hesitate to 
contact me here at the Embassy.  

Sincerely, 
 
Signed by: 

Charles R. Paul:  
Ambassador:  

[End of letter] 

Response And Comments Of The Government Of The Republic Of The 
Marshall Islands To The U.S. Government Accountability Office Report 
"Compacts Of Free Association, Improvements Needed To Assess And 
Address Growing Migration" 

The Government of the Republic of the Marshall Islands (GRMI) wishes to
congratulate the United States Government Accountability Office (GAO) 
for its draft report "Compacts of Free Association, Improvements 
Needed to Assess and Address Growing Migration" (Report). Although 
questions and issues remain, this is the first objective effort to 
examine an issue of growing importance to the Freely Associated States 
(FAS), and "affected jurisdictions" within the United States. A fair 
and objective assessment of "Compact Impact" costs is long overdue, 
and the GRMI appreciates the efforts of the GAO in providing an 
initial effort at an honest and impartial assessment of these issues 
that have become so highly charged in the past year. 

Technical Comments: 

1. The GRMI notes that on the first page summary of the Report, GAO 
concludes that: "Compact migrants participate in local economies 
through employment, taxation, and consumption, but data on these 
effects are limited." The GRMI believes that not including RMI citizen 
contributions to the economies of "affected jurisdictions" (and 
elsewhere) is a serious flaw, undermining the credibility of claimed 
Compact Impact costs. Although challenging, a methodology needs to be 
developed that determines "net" Compact costs.[Footnote 1] Not 
including contributions encourages a system that tracks RMI citizens 
living in the United States to determine negative impact only, (solely 
for purposes of seeking reimbursement of impact expenses), while not 
taking into account the benefits, including revenues accruing to 
affected jurisdictions resulting from RMI citizen migration. The GRMI 
does not claim that these contributions will equal costs or expenses, 
but will at least give everyone a more accurate and fair picture of 
Marshallese migration to the United States, its impact, as well as its 
benefits. [See comment 1] 

The GAO has recognized this deficiency in their conclusions and is
recommending that action be taken to correct this and other 
significant problems with the enumeration process and determining 
impact costs or expenses. The GRMI requests that the contributions of 
RMI citizen participation in the Armed Forces of the United States 
also be taken into account. [See comment 2] 

2. The Report indicates that the largest cost claimed by affected 
jurisdictions seems to be in the area of education. Noted, although 
not addressed in the report is that a number of Marshallese migrants 
attending public schools in the United States are in fact U.S. 
citizens. Although, they may also be dual citizens, and may legally be 
included for purposes of Compact impact costs,[Footnote 2] the GRMI 
questions the inclusion of U.S. citizens in determining impact 
expenses and costs. When this is done without regard to citizenship, 
the process becomes one of identifying individuals based on ethnic 
background. There should be an effort in the enumeration process to 
determine the number of Marshallese who are U.S. citizens. [See 
comment 3] 

[Pages in the draft report may differ from those in this report] 

3. Page 7 of the Report refers to Congress acting sympathetically and
expeditiously to redress any adverse consequences and authorized 
compensation for affected jurisdictions that might experience 
increased demands on their educational and social services by compact 
migrants from the Marshall Islands and Micronesia. Footnote 14 on page 
7 further states that the amended compacts' enabling legislation 
authorized additional appropriations for grants to affected 
jurisdictions to offset impact. The GRMI would reiterate this point 
since it is the existing system already put in place, and that it is 
the responsibility of Congress to provide that the affected 
jurisdictions are fairly compensated for any adverse impact. 

4. Page 33 of the Report discusses where and how the compact impact 
grants have been used. Examples include general support of local 
budgets, projects, and for specific departmental purchases in the 
areas of health, education, public safety, and social services. Also, 
in the last pages of the report, there is a table that list the 
projects for Guam, Hawaii, etc that were eligible for compact impact 
grants. Many of the projects are questionable and don't
seem to address compact impact issues. The suggestions (page 35) to 
use these funds in areas such as language and cultural assistance, job 
training, improved access to basic services, and so forth seem much 
more appropriate for compact impact grants. Presently, it would appear 
that some of the existing Compact impact funds are not used properly 
to address compact impact issues. 

5. The GRMI believes that it would be helpful to provide government 
leaders and decision makers with comparative information on 
emigration, or migration rates from other Pacific Island nations such 
as Kiribati, Tuvalu, Samoa, Tonga, Cook Islands, Niue, etc. Although 
the political and legal relationships in these nations are different 
from the FAS, we believe that emigration/migration rates in these 
nations over time are consistent with, and in some cases much greater 
than Marshallese migration to the United States. We also believe this 
to be true of migration rates of citizens from U.S. flag island 
territories to the U. S. mainland. This simply reflects the fact that 
opportunities in the islands are limited, and people will often 
migrate or emigrate in order to seek more and better opportunities 
than a small island economy can provide. [See comment 4] 

6. The GRMI believes that some of the data for enumerations for 
Marshallese in the State of Hawaii may be erroneous and overstated 
since some Marshallese only transit Hawaii for a short period before 
moving to the U.S mainland to accept employment. There is a 
substantial amount of anecdotal evidence that would indicate that many 
Marshallese enter the U.S. through Hawaii, and stay there for a 
limited amount of time until relatives living in the mainland identify 
suitable employment opportunities for them that don't exist in
Hawaii. [See comment 5] 

Political and Policy Issues: 

1. The GRMI views the immigration privileges in the Compact as a 
fundamental cornerstone in the relationship of "free association", 
similar to how the U.S. views its prerogatives in the security and 
defense provisions of the Compact. 

2. When the Compact, as amended, was negotiated in 2000-2003, the U.S. 
and RMI agreed on the major objectives of accountability (with respect 
to financial assistance), and a greater emphasis on health and 
education in the RMI itself so that our nation would have better 
educated and healthier citizens who will better contribute to their 
nation in the islands, or as migrants in the United States. 

Although "Compact Impact" was also an issue at that time, both 
governments realized that the solution to these challenges was to 
improve health and education in the Marshall Islands. That continues 
to be the case. The GRMI has made a dedicated and disciplined effort 
in this respect since the amended Compact first came into effect. The 
GRMI has maintained a strong core commitment and emphasis on health 
and education along with related infrastructure while maintaining 
accountability. The GRMI is in compliance with its Compact commitments. 

Achieving our mutual goal will take time and patience, however. The 
GRMI cannot overcome problems that date back to the Trust Territory 
period in a matter of only a few years. Resorting to draconian changes 
in immigration privileges by imposing a "de facto visa" as a few 
members of Congress have been recommending will not resolve the 
problem. Rather, it will only exasperate the problem and lead to an 
overall deterioration in the relationship. 

3. The GRMI believes that the Report does not provide any rational or 
reasonable basis to proceed with unilateral imposition of regulations 
pertaining to the rights and privileges of Marshallese to enter, live, 
work, and establish residence in the United States under the Compact. 
To the contrary, the Report shows that much work needs to be done in 
terms of providing fair and accurate data to support claims of Compact 
impact costs and expenses. 

4. Although there is discussion in the Report regarding JEMFAC taking 
action to deal with Compact impact costs in affected jurisdictions in 
the United States, GRMI would point out that Compact Sector Grants 
were never designed or funded for that purpose. The language contained 
is Section 211 of the Compact, and Fiscal Procedures Agreement relate 
only to activities in the RMI. [See comment 6] 

Funding is also woefully inadequate for this task, and the GRMI notes 
that annual sector grant assistance is subject to a decrement of 
$500,000 each year through 2023. Thus, the GRMI must grapple with the 
accumulated effects of this decrement on health and education budgets 
which will make it very difficult to maintain existing health and 
education investments. The GRMI has pointed this out in numerous bi-
lateral meetings with the US Government including the JEMFAC as well 
as through the Section 104(h) Five Year Compact Review. 

S. The GRMI believes that the Compact impact issue is ancillary to the 
overall Compact relationship. Nonetheless, GRMI wants its citizens who 
migrate to the United States to be good citizens and positive 
contributors to the communities in which they reside. One of the ways 
in which this can be advanced is by assuring that our citizens don't 
travel overseas (to the U.S. or elsewhere) with certain highly 
communicable diseases. The GRMI is in the process of setting up a 
special task force which will prioritize working on and implementing a 
program to provide that assurance in conjunction with the Ministry of 
Health budget and other resources to address these diseases. 

The GRMI has used previous Department of Interior technical assistance 
to prepare a video for Marshallese intending to migrate to the United 
States that describes intending migrants' rights, duties, and 
responsibilities while living in the United States. This video has 
been widely shown on cable television in the RMI, and is available for 
viewing at the Office of the Attorney General where passports are 
processed. 

Appendix XV Footnotes: 

[1] It is noteworthy that subsection (e)(2) of Section 104 of P.L. 108-
188 does not define the term impact costs, or expense. 

[2] Subsection (e)(2)(B) of Section 104 of P.L. 108-188 defines 
"qualified nonimmigrant" to include dependents under the age of 18. 

The following are GAO's comments on the Marshall Islands government's 
letter dated October 14, 2011. 

GAO Comments: 

1. The government of the Marshall Islands stated that not including 
Marshallese citizen contributions to the economies of U.S. areas is a 
serious flaw that undermines the credibility of claimed compact impact 
costs. The Marshall Islands recommended that a methodology be 
developed that determines "net" compact costs. The amended compacts' 
enabling legislation does not require the inclusion of such data in 
affected jurisdictions' impact reports and complete data on compact 
migrants' contribution to local economies does not exist. We provided 
available information on labor market participation, taxes, 
consumption, and remittances. 

2. The government of the Marshall Islands asked that the participation 
of Marshall Islands citizens in the armed forces of the United States 
also be taken into account. We have obtained data from the Department 
of Defense on persons born in the FAS who are on active duty in the 
U.S. armed forces and have added this to the report. 

3. The government of the Marshall Islands noted that a number of 
Marshallese migrants attending public schools in the United States are 
U.S. citizens and that, while they may legally be included for 
purposes of compact impact costs, it questioned the inclusion of U.S. 
citizens in determining impact costs. As our report notes, Interior 
interprets the legislation's definition of qualified nonimmigrant--
which generally refers to a compact migrant living in an affected 
jurisdiction--as including those migrants' children under the age of 
18 who are born in the United States; therefore, some U.S. citizens 
are included in the count of compact migrants. The Census ACS 
tabulation we obtained for our estimates used Interior's definition of 
a compact migrant. The ACS interviews current residents--that is, 
those in the house on the day of the interview who have been staying 
there for more than 2 months, regardless of the individuals' usual 
residence. 

4. The government of the Marshall Islands stated that it would be 
helpful to provide government leaders and decision makers with 
comparative information on emigration, or migration rates from other 
Pacific Island nations. This analysis was not part of the scope of our 
audit. 

5. The government of the Marshall Islands stated that some of the data 
for enumerations for Marshallese in the state of Hawaii may be 
erroneous and overstated since some Marshallese only transit through 
Hawaii for a short period before moving to the U.S. mainland to accept 
employment. We do not have data to verify this assertion. 

6. The government of the Marshall Islands stated that although there 
is discussion in the report regarding U.S.-Marshall Islands joint 
management committee taking action to deal with compact impact costs 
in affected jurisdictions in the United States, sector grants were 
never designed or funded for that purpose. In response to the 
government of the Marshall Islands and other comments, we clarified 
our recommendation regarding compact sector grants to not imply that 
the use of sector grants to address migration concerns should be in 
the affected jurisdictions. We also note that, though we did not find 
instances of the Marshall Islands using grant funds for activities in 
affected jurisdictions, the FSM has done so in Guam. 

[End of section] 

Appendix XVI: Comments from the Government of the Republic of Palau: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

Embassy of the Government of the Republic of Palau: 
1701 Pennsylvania Avenue, NW; Suite 300: 
Washington, DC 20006: 
Phone 202-452-6814: 
Fax 202-452-6281: 
[hyperlink, http://www.palauernbassy.com] 

14 October 2011: 

Mr. Emil Friberg: 
Assistant Director, International Affairs & Trade: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 30548: 

Dear Mr. Friberg: 

I write on behalf of the Government of the Republic of Palau to 
comment on the draft GAO report entitled Improvements Needed to Assess 
and Address Growing Migration, GAO-12-64. Thank you for the 
opportunity. 

At the outset we note that the draft report is a very thorough. 
Without prejudice to our review of and comments on the final product, 
for the most part we concur with the statements contained in the 
draft, with the following caveats specifically excepted. We also note 
that the draft report is lengthy and therefore the comments set forth 
below may concern matters that were contained in the draft but 
overlooked in our perusal of it. 

We suggest that certain terminology used in the draft report be 
changed to avoid confusion. Throughout the draft report the word 
"Micronesian" is used to refer to the citizens of the Federated States 
Micronesia. While of perhaps technically this is an acceptable use of 
the word, in this part of the world, throughout most of the Pacific, 
and certainly in the so-called affected jurisdictions of Guam and 
Hawaii, the word "Micronesian" is commonly understood to include not 
only those islands comprising the Federated States of Micronesia, but 
also the islands of Republic of the Marshall Islands, the Republic of 
Palau, and even islands of Saipan, Guam. Since the report is being 
generated for the consumption of people living in this area there will 
be a tendency to understand the word "Micronesian" to include more 
than just the citizens of the Federated States of Micronesia. Hence, 
we suggest that instead of using the word "Micronesians" in referring 
to the citizens of the Federated States of Micronesia, that the phrase
"citizens of the FSM" be utilized instead. [See comment 1] 
 
In our opinion, the draft report does not adequately address the lack 
of information regarding what we refer to as "positive impact" that 
has occurred by reason of the emigration of FAS citizens to the United 
States. [See comment 2] The complaints of the affected jurisdictions 
concerning the impact of the emigration of FAS citizens to the United 
States to is in the relate what perceived affected jurisdictions as 
the negative impact of the emigration. Ultimately, whatever policies 
are established in connection with this matter must take into 
consideration the positive impact: the fact that the vast majority of 
FAS emigrants are gainfully employed, often times in jobs that U.S. 
citizens themselves are not willing to work;[Footnote 1] the fact that 
many FAS citizens serve in the U.S. Armed Forces and fight side-by-
side with U.S. citizens; the fact that the FAS emigrants pay taxes, 
participate in their communities, and generally positively contribute 
to the economies of the areas where they live. [See comment 3] 

We commend the draft report to the extent it recognizes that much of 
the information relating to the impact of FAS emigrants is not very 
accurate and often anecdotal at best. We have long suspected that much 
of the perceived adverse impact is not well grounded in fact and even
exaggerated in some instances. Contrary to one portion of the draft 
report that states some agencies may not have included capital costs 
in their impact reporting, we perceive that most have done so, thus 
contributing to a gross overstatement of the costs associated with FAS
emigration. Unless an affected jurisdiction actually had to build a 
new school or hospital or other facility to accommodate the FAS 
emigrants, it is our position that the infrastructure would have 
existed in any event and should not be considered in the equation. 
[See comment 4] 

We think that the draft report does not adequately explore whether the 
impact of the FAS emigrants to the United States differs from FAS 
country to FAS country. During his visit to Washington in June, Palau 
President Johnson Toribiong was told personally by Members of the
U.S. Senate and House of Representatives from jurisdictions with large 
numbers of compact migrants that Palauans were not the cause of any 
adverse impact in their respective jurisdictions. [See comment 5] 

Palau is a sovereign state, separate and distinct from the FSM the 
RMI. Palau's Compact of Free Association ("COFA") is separate and 
distinct from the COFA's of the FSM and RMI. Palauans are ethnically 
and linguistically distinct from the other areas of Micronesia and
historically, except for neighboring Yap, had little or no commerce 
with the other areas of Micronesia. Palau's population is 
significantly smaller than the populations of the other FAS countries, 
yet Palau's economic development is significantly greater, thus giving 
Palauans less of an imperative to migrate. It is one thing to review 
the impact of emigration from all of the FAS countries, but in 
formulating policies on how to deal with the impact, it is imperative 
that the impact of each FAS country be quantified separately. 

For instance, any report involving Palawan migrants first needs to 
distinguish between those who are present in the United States solely 
by virtue of the COFA and those who are in the United States under the 
auspices of other laws. The draft report states on page 13, [now on p. 
15] that Palauans comprise about 9% or roughly 5,000, of the estimated 
56,000 FAS migrants living in the United States. This is an accurate 
estimate, but it has to be understood that many, if not most, Palauans
in the United States emigrated long before the COFA came into effect, 
some as far back as the late 1940's and early 1950's, some as refugees 
of World War II, and that they are scattered throughout the United 
States. While ethnically these people are Palauans and perhaps would 
identify themselves as such on a census form, they also are U.S. 
citizens or Green Card holders—as are their children, grandchildren, 
and in many cases, their great-grandchildren—and thus should not he 
considered in calculating the impact of FAS emigration. [See comment 6] 

For instance, our own numbers for Hawaii—admittedly anecdotal, but 
believed to be fairly accurate given the small size of the Palauan 
community—indicate that the adverse impact of Palauans emigrants in 
Hawaii is non-existent. Ethnic Palauans in Hawaii are categorized as
follows: U.S. citizens, either by birth or through naturalization; 
U.S. permanent resident aliens (Green Card holders); members of the 
U.S. Armed Forces and their dependents; and, finally the Palauan 
migrants who are in Hawaii solely under the auspices of the COFA. [See 
comment 7] The latter category of Palauans in Hawaii numbers about 350 
disbursed throughout Hawaii, about 35 of whom are children attending 
public and private schools from K-High School.[Footnote 2] Although 
all of the students are eligible for the student health program 
sponsored by the State of Hawaii, not all of them use it as they are 
covered by their parents' job provided health insurance. To our 
knowledge, not more than five Palauan adults per year have requested 
health related assistance from the State of Hawaii, and some of those 
were temporary transients who encountered health problems and were 
advised to apply for the program. It is difficult to ascertain the 
number of Palauans in this latter category who are on welfare due to 
privacy laws and a reluctance of people to discuss the matter, but we 
believe that fewer than five of them have utilized Hawaii State 
housing assistance programs. Of those five unfortunates, one has gone 
back to Palau and one is a beneficiary of industrial health/accident 
benefits for which he will be disqualified should he move out of the 
state. Finally, except for Palauans sent to Triple/Hospital by the Palau
Government pursuant to U.S. Department of Defense funded programs, 
which pay for all of the costs, no Palauans are known to have 
emigrated to Hawaii of any other state or affected jurisdiction to 
receive medical care not otherwise available in Palau. 

Finally, since the affected jurisdictions and the Department of 
Interior have been unable in the past to agree amongst themselves on a 
method of enumerating the affects of the FAS emigrants, we suggest 
that your agency suggest the approach that should be utilized. We also 
suggest that an eCensus enumeration be considered. 

Thank you again for the opportunity to comment. 

Sincerely yours, 

Signed by: 

Henry Kyota: 
Ambassador: 

Appendix XVI Footnotes: 

[1] As an aside, the most recent wave of Palauans emigrating to the 
U.S. under the terms of the COFA were recruited to go to the U.S. to 
work in poultry and meatpacking plants in the Midwest. 

[2] For Guam the actual numbers in this category of emigrants are 
about 673 Palauans residing in Guam solely under the auspices of the 
COFA provisions, consisting of 452 adults, and 221 children under the 
age of 18. The rest of the ethic Palauans living in Guam are U.S. 
citizens, permanent residents, or members of the armed forces. 

The following are GAO's comments on the Palau government's letter 
dated October 14, 2011. 

GAO Comments: 

1. The government of Palau noted that our draft report's use of the 
term "Micronesian" to refer to citizens of the Federated States of 
Micronesia may be confusing, as Micronesian also has a larger meaning 
related to persons living on multiple Pacific islands. We have 
reviewed the report and now refer to the Federated States of 
Micronesia as the FSM. In keeping with a commonly used definition, we 
use the term "Micronesia" to refer to the three compact nations. 

2. The government of Palau stated that our report does not adequately 
address the lack of information regarding "positive impact" from 
compact migration. The amended compacts' enabling legislation does not 
require the inclusion of such data in affected jurisdictions' impact 
reports, and complete data on compact migrants' contribution to local 
economies does not exist. We provided available information on labor 
market participation, taxes, consumption, and remittances. 

3. The government of Palau noted that FAS citizens serve in the U.S. 
armed forces. We have obtained data from the Department of Defense on 
persons born in the FAS who are on active duty in the U.S. armed 
forces and have added this to the report. 

4. The government of Palau stated that most agencies have included 
capital costs in their impact reporting, thus contributing to a gross 
overstatement of the costs associated with migrants. However, in our 
review, we did not find cases where agencies included such capital 
costs in their impact reporting. Such costs could be legitimate and 
addressed by future Interior guidelines. 

5. The government of Palau stated that our report does not adequately 
explore the differences in the impact between the three FAS. Not all 
local government agencies reported compact impact costs by FAS 
country, and this assessment was not included in the scope of our 
review. Complete data on compact migrants' contribution to local 
economies does not exist; however, we provided available information 
on labor market participation, taxes, consumption, and remittances. If 
Interior implements our recommendation to disseminate adequate 
guidance on compact impact reporting to affected jurisdictions, 
assessing impact by FAS country may be a topic for Interior to address. 

6. The government of Palau stated that our estimate of Palauan 
migrants is an accurate estimate, but that many Palauans emigrated 
before the compacts came into effect and, while ethnically Palauan, 
should not be considered in calculating the impact of FAS emigration. 
However, the Census tabulation and survey we used in estimating the 
number of Palauan compact migrants only included those who arrived in 
U.S. areas after the date of the Palau compact. Those who arrived in 
the United States prior to that date, and their children, are not 
included in our estimate. 

7. The government of Palau noted that ethnic Palauans in the United 
States may be U.S. citizens, permanent resident aliens (Green Card 
holders), or members of the U.S. Armed Forces and their dependents, as 
well as compact migrants. As our report notes, Interior interprets the 
legislation's definition of qualified nonimmigrant--which generally 
refers to a compact migrant living in an affected jurisdiction--as 
including those migrants' children under the age of 18 who are born in 
the United States; therefore, some U.S. citizens are included in the 
count of migrants. However, we agree with Palau's comment that some 
persons who entered the United States after the date of the compacts 
may be lawfully present in U.S. areas under authorities other than 
those of Section 141 of the compacts and have noted this in the report. 

[End of section] 

Appendix XVII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David B. Gootnick, 202-512-3149 or gootnickd@gao.gov: 

Acknowledgments: 

In addition to the contact named above, Emil Friberg, Jr., Assistant 
Director; Keesha Egebrecht; Fang He; Reid Lowe; Mary Moutsos; Michael 
Simon; Sonya Vartivarian; Adam Vogt; Greg Wilmoth; and Monique 
Williams made key contributions to this report. Michael Derr, Bob 
Lunsford, and Jena Sinkfield provided additional technical assistance. 

[End of section] 

Footnotes: 

[1] In this report, we refer to the Federated States of Micronesia as 
FSM. In keeping with a commonly used definition, we use the term 
"Micronesia" to refer to the three compact nations. See, for example, 
Francis X. Hezel, Strangers in Their Own Land: A Century of Colonial 
Rule in the Caroline and Marshall Islands, (Honolulu, Hawaii, 
University of Hawaii Press, 1995), xv. 

[2] In this report, "U.S. areas" refers to the 50 U.S. states; the 
U.S. insular areas (Guam, the CNMI, American Samoa, and the U.S. 
Virgin Islands); Puerto Rico; and the District of Columbia. 

[3] Compact of Free Association Amendments Act of 2003, Pub. L. No.108-
188, December 17, 2003. In this report, the act is referred to as "the 
amended compacts' enabling legislation." 

[4] In this report, "compact migrants" refers to persons from the FSM, 
the Marshall Islands, and Palau and their children younger than 18 
years who, pursuant to the compacts, were admitted to, or have resided 
in, U.S. areas since, respectively, 1986 for the FSM and the Marshall 
Islands and 1994 for Palau. Because of American Samoa's small reported 
FAS population--estimated at 15 in the 2008 enumeration--this report 
does not address compact migrants in American Samoa. 

[5] We previously reported on compact migrants and their impact in 
GAO, Foreign Relations: Migration From Micronesian Nations Has Had 
Significant Impact on Guam, Hawaii, and the Commonwealth of the 
Northern Mariana Islands, [hyperlink, 
http://www.gao.gov/products/GAO-02-40] (Washington, D.C.: Oct. 5, 
2001). 

[6] OMB, Questions and Answers When Designing Surveys for Information 
Collections (Washington, D.C.: 2006) and Standards and Guidelines for 
Statistical Surveys (Washington, D.C.: 2006). 

[7] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009) 
and OMB Circular No. A-94, Guidelines and Discount Rates for Benefit-
Cost Analysis of Federal Programs, revised October 29, 1992. 

[8] The 2008 population of the three FAS is equivalent to about 0.06 
percent of the 2010 U.S. population of 308.7 million, and roughly the 
same as the 2010 population of Knoxville, Tennessee. 

[9] According to the U.S. Department of State, approximately 6,000 of 
the Palau population consists of third-country nationals, mostly from 
the Philippines, who are not Palau citizens and therefore not eligible 
to migrate under the terms of the compact. 

[10] The four states of the FSM are Chuuk, Kosrae, Pohnpei, and Yap. 

[11] Under the United Nations trusteeship agreement, the United States 
became administratively responsible for the Trust Territory of the 
Pacific Islands: the FSM, the Marshall Islands, Palau, and the 
Northern Mariana Islands. In 1975, the Northern Marianas became a 
commonwealth in political union with the United States. 

[12] Compact of Free Association Act of 1985, Pub. L. No. 99-239, 
January 14, 1986. 

[13] See Proclamation 6726, Placing into Full Force and Effect the 
Compact of Free Association with the Republic of Palau, 59 Fed. Reg. 
49777 (Sept. 27, 1994) and Palau Compact of Free Association, Pub. L. 
No. 99-658 (Nov. 14, 1986). 

[14] Guam Omnibus Opportunities Act, Pub. L. No. 106-504, Sec. 2, 
November 13, 2000. 

[15] Under the amended compacts, compact migrants from the FSM and 
Marshall Islands need a valid passport in order to be admitted into 
the United States. 

[16] In November 2011, Representative Hanabusa of Hawaii introduced 
H.R. 3320, a bill to "amend the Compact of Free Association of 1985 to 
provide for adequate compact-impact aid to affected States and 
territories, and for other purposes." Among other provisions, the bill 
proposes to increase annual compact impact grants to $185 million 
beginning in fiscal year 2012. 

[17] The amended compacts' enabling legislation, Sec. 104 (e)(6), also 
"authorized to be appropriated to the Secretary of the Interior such 
sums as may be necessary to reimburse health care institutions in the 
affected jurisdictions for costs resulting from the migration of 
citizens of the Republic of the Marshall Islands, the Federated States 
of Micronesia and the Republic of Palau to the affected jurisdictions 
as a result of the implementation of the Compact of Free Association." 
The amended compacts' enabling legislation, Sec. 104 (e)(7), required 
the Secretary of Defense to make Department of Defense medical 
facilities available to properly referred citizens of the FSM and 
Marshall Islands on a space available and reimbursable basis. 

[18] The amended compacts' enabling legislation, Sec. 104 (e)(10), 
authorized additional appropriations to "the Secretary of the Interior 
for each of fiscal years 2004 through 2023 such sums as may be 
necessary for grants to the governments of Guam, the State of Hawaii, 
the CNMI, and American Samoa, as a result of increased demands placed 
on educational, social, or public safety services or infrastructure 
related to service due to the presence in Guam, Hawaii, the CNMI, and 
American Samoa" of compact migrants from the three FAS. To date 
Congress has not provided additional appropriations. Sec. 104 (e)(9) 
authorized the President to reduce, release, or waive amounts owed by 
the governments of Guam and the CNMI to the United States to address 
unreimbursed impact expenses incurred prior to the end of fiscal year 
2003. Guam requested, but did not receive, such debt relief. The 
authority granted in Sec. 104 (e)(9) expired February 28, 2005. 

[19] Interior interprets the legislation's definition of compact 
migrant as including children of those migrants under the age of 18 
who are born in the United States. 

[20] The $3.6 billion in assistance includes (1) compact sector 
grants; (2) contributions to a trust fund for each of the countries; 
(3) Kwajalein impact funding provided to the Marshall Islands 
government; (4) estimated values of compact-authorized federal 
services, such as weather, aviation, and postal services over the 20-
year period; and (5) inflation adjustments. This amount does not 
include services related to disaster relief. For more information 
about U.S. assistance provided under the amended compacts, see 
Compacts of Free Association: Micronesia's and the Marshall Islands' 
Use of Sector Grants, [hyperlink, 
http://www.gao.gov/products/GAO-07-514R] (Washington, D.C.: May 25, 
2007). 

[21] The Palau compact makes no provision for a grant management 
entity. In addition to the U.S. assistance provided under the Palau 
compact, U.S. agencies provide discretionary federal programs in Palau 
as authorized by U.S. legislation and with appropriations from 
Congress. The compact's federal programs and services subsidiary 
agreement, establishing the legal framework for the provision of 
discretionary federal programs in Palau, was in force until October 1, 
2009. These services continued under program authority in 2010 and 
2011. 

[22] In this report, we use "demographic" to encompass demographic, 
social, economic and housing data. 

[23] The initial survey was conducted in 1992 in Guam and 1993 in the 
CNMI; Hawaii was not surveyed at that time. The second survey was 
conducted in Guam and Hawaii in 1997 and the CNMI in 1998. In addition 
to these surveys, a 1995 survey of Palauans on Guam identified 2,276 
Palauans, 1,014 of whom were born in Palau. 

[24] As a nonprobability survey, the snowball technique results in a 
count of compact migrants rather than a statistical estimate of that 
population with a determined level of precision and is likely to 
undercount them. 

[25] Census divided Guam and the CNMI into mutually exclusive 
geographic units called blocks and selected a random sample of blocks. 
In each selected block, Census workers surveyed all housing units or a 
random subsample of the units, depending on the block's size. In a 
probability survey, every member of the population has a known, non- 
zero chance of being included. 

[26] In the CNMI, Census surveyed only the island of Saipan. Because 
few migrants and approximately 10 percent of the total CNMI population 
live on the CNMI's other inhabited islands Census estimated the 
migrant population on the other islands using data from the 2000 
decennial census. 

[27] Of this amount, $316,000 came from the 2008 compact impact funds 
for the affected jurisdictions, with the remainder drawn from Interior 
technical assistance funds. According to Census officials, nearly all 
costs for the 2008 enumeration were associated with the Guam and CNMI 
surveys. 

[28] In contrast to a census, which produces a population count, the 
ACS is a statistical survey and produces estimates with a range of 
uncertainty. Census's 2005-2009 ACS and 2008 enumerations estimated 
the total number of compact migrants in U.S. states and territories as 
ranging from 49,642 to 63,048, with a 90 percent confidence interval; 
that is, Census is 90 percent confident that the true number of 
compact migrants falls within that range. Both the Census tabulations 
of ACS data and the 2008 migrant enumeration defined migrants based on 
their place of birth in the FAS and arrival in U.S. areas after the 
date of the compact. In some cases, however, persons may be born in 
the FAS and arrive after the date of the compact, but be present in 
the United States under authorities other than those of the compact. 
For example, they may be permanent resident aliens (green card 
holders) or members of the U.S. armed forces. 

[29] In addition to compact migrants, there are additional FSM 
citizens, Marshallese, and Palauans who arrived prior to the compacts 
in U.S. areas. For example, the 2003 survey of Micronesians counted 
3,909 pre-compact migrants. An unknown number of FAS citizens may also 
live in other countries. 

[30] In some cases the lower bound of the 90 percent confidence 
interval is below 1,000. The confidence intervals for a number of 
these states overlap, indicating that the estimated number of migrants 
in these states may be statistically equivalent. As a result, for 
example, the estimated range for the true number of migrants in Utah 
overlaps with the estimated range for the true number in California. 
See appendix III for a table of estimates by state and FAS, including 
confidence intervals. The government of Hawaii observed that ACS data 
are inadequate for small groups like compact migrants. We address 
these limitations in detail in appendix V. 

[31] Interior's 1998 survey reported 11,140 compact migrants from the 
FSM; 2,267 from the Marshall Islands; and 407 from Palau. The 2003 
survey reported 15,514 compact migrants from the FSM; 2,901 from the 
Marshall Islands; and 2,283 from Palau. 

[32] In contrast, the snowball technique used for the 1993, 1998, and 
2003 surveys is a nonprobability method and, as such, cannot calculate 
the margin of error of its data to report on its potential miscount. 

[33] All methods for conducting the enumeration have some limitations. 
In addition to those we discuss, surveys are subject to error that 
potentially affect their estimates. Fears of deportation from the 
affected jurisdiction or eviction from housing may have inhibited some 
migrants from participating in the survey or from fully disclosing 
their personal information. For example, according to some officials 
in affected jurisdictions, migrants tend to live in crowded 
conditions, in some cases violating the terms of their lease. Migrants 
may therefore have feared that disclosing their true numbers could get 
them evicted. See appendix V for a more detailed presentation of the 
attributes that could contribute to survey error. 

[34] Although the prior enumerations used the same methodology--the 
snowball technique--in each affected jurisdiction, it involved 
assumptions (e.g., the geographic concentration of compact migrants) 
that, if they were not met in each jurisdiction to a similar extent, 
would cause the data to not be directly comparable across the affected 
jurisdictions. 

[35] Approximately 7,000 persons are estimated to have left the FSM in 
fiscal years 2007 and 2008 and the Marshall Islands in calendar years 
2007 and 2008, as measured by net air passengers from the United 
States. See U.S. Department of the Interior Office of Insular Affairs 
and Pacific Islands Training Initiative, Federated States of 
Micronesia: Fiscal Year 2008 Economic Review (2009) and Republic of 
the Marshall Islands: Fiscal Year 2009 Economic Review (2010). 

[36] If statistically valid trend estimates are desired, an 
appropriate methodology specifically designed to estimate trends is 
necessary. 

[37] Guam received a public use sample that allowed the construction 
of additional tables by age, family relationship to respondent, 
gender, place of birth, and year of entry. 

[38] In 2001, we found that the 1998 enumeration of compact migrants 
in Guam, Hawaii, and the CNMI, using the snowball method, likely 
undercounted compact migrants (see [hyperlink, 
http://www.gao.gov/products/GAO-02-40]). 

[39] See OMB, Standards and Guidelines for Statistical Surveys 
(Washington, D.C: 2006). Census sought and received OMB approval for 
the method used in 2008; Census did not ask OMB to consider the method 
used in 2003 in 2008. Census did not discuss with the affected 
jurisdictions whether the snowball survey would meet separate OMB 
criteria for nonstatistical data collection efforts. According to OMB, 
Questions and Answers When Designing Surveys for Information 
Collections (Washington, D.C.: 2006), information that agencies 
collect must be useful and methods used must be appropriate for the 
intended use of the information. In addition to permitting data 
collection as a response to a specific legal requirement, OMB permits 
collection of data in response to "knowledge gaps." 

[40] According to Census officials, if Census conducts an enumeration 
of compact migrants in 2018 it plans to use, as in 2008, a special 
survey for Guam and the CNMI and the ACS for Hawaii in 2018. 

[41] As it is a full census and not a sample, there is no sampling 
error in the 2010 census. However, the census for Guam and CNMI, like 
any census, may not reach all persons and therefore the reported 
results might be an undercount. 

[42] For example, for the 2010 decennial census, Census posted 
documents in the languages of the Marshall Islands and Chuuk state, 
the most populous state in the FSM. 

[43] For 1986 through 2003, affected jurisdictions reported total 
compact impact costs of approximately $540 million to $568 million 
(unadjusted for inflation). 

[44] When noting these concerns affecting compact migrants, various 
officials noted that the concerns are similar to those faced by other 
newly arriving populations. 

[45] Data from the 2003 Surveys of Micronesian Migrants estimated that 
less than 54 percent of compact migrants graduated from high school 
and that less than 4 percent of compact migrants graduated from 
college. Migrants from Palau generally had higher educational 
attainment than migrants from the FSM and the Marshall Islands. 

[46] In March 2011, Representative Bordallo of Guam introduced H.R. 
888, a bill that would amend the Impact Aid program of the Elementary 
and Secondary Education Act of 1965 to compensate local educational 
agencies for educating children who were admitted into the United 
States as citizens of one of the FAS. Currently such impact aid 
provides financial assistance to local educational agencies that 
educate children who, among others, reside on Indian lands or have a 
parent on active military duty. 

[47] For studies of health issues affecting FAS citizens see, for 
example, Asian and Pacific Islander American Health Forum, Native 
Hawaiian and Pacific Islander Health Disparities (2010), available at 
[hyperlink, http://www.apiahf.org/resources/]; and Ann M. Pobutsky, 
Lee Buenconsejo-Lum, Catherine Chow, Neal Palafox, Gregory G. 
Maskarinec, "Micronesian Migrants in Hawaii: Health Issues and 
Culturally Appropriate, Community-Based Solutions," Californian 
Journal of Health Promotion, vol. 3, no. 4 (2005): 59-72. 

[48] Data from the 2003 Surveys of Micronesian Migrants in the CNMI, 
Guam, and Hawaii estimated that compact migrants' per capita incomes 
were less than $5,700 and had poverty rates above 43 percent. 

[49] When the compacts were signed, FAS citizens were eligible for 
Medicaid; however, the Personal Responsibility and Work Opportunity 
Reconciliation Act of 1996 (PRWORA) removed this eligibility. Hawaii 
chose to continue to provide equivalent services at its own expense. 
Guam and the CNMI, unlike states, are subject to annual caps on 
federal funds for Medicaid; once this cap is reached, each area must 
provide for the cost from its own funds. For further information, see 
GAO, U.S. Insular Areas: Multiple Factors Affect Federal Health Care 
Funding, [hyperlink, http://www.gao.gov/products/GAO-06-75] 
(Washington, D.C.: Oct. 14, 2005). In September 2009, Hawaii stopped 
providing nonpregnant adult compact migrants with benefits equivalent 
to the state's Medicaid coverage plan and transferred them to a new 
program known as Basic Health Hawaii, which provided less coverage. 
The resulting litigation prompted a temporary injunction blocking 
implementation of Basic Health Hawaii and a return to compact migrant 
eligibility for Medicaid-like benefits. At the time of our review, the 
case was still under litigation. In March 2011, Representative Hirono 
of Hawaii introduced H.R. 1035, a bill that would amend title IV of 
PRWORA to permit Medicaid coverage for FAS citizens. In August 2011, 
Senator Akaka of Hawaii introduced S.1504, which would also restore 
Medicaid eligibility for FAS citizens. 

[50] For a description of our methodology in examining the compact 
impact reports, see appendix I. For a discussion of recommended cost 
estimation practices, see GAO, Cost Estimating and Assessment Guide: 
Best Practices for Developing and Managing Capital Program Costs, 
[hyperlink, http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: 
March 2009) and OMB Circular No. A-94, Guidelines and Discount Rates 
for Benefit-Cost Analysis of Federal Programs, revised October 29, 
1992. 

[51] The amended compacts' enabling legislation Sec 104 (e)(2)(B), 
states that a qualified nonimmigrant means a person, or their children 
under the age of 18, admitted or resident pursuant to section 141 of 
the compacts who, as of a date referenced in the most recently 
published enumeration, is a resident of an affected jurisdiction. Thus 
qualified nonimmigrants would refer to compact migrants, as the term 
is used in this report, who are residents of an affected jurisdiction. 

[52] In 2003, Interior's survey estimated that 28 percent of compact 
migrants were born in the affected jurisdiction in which they lived. 

[53] A further refinement is to consider the incremental cost of 
providing service to a compact migrant. If an agency has unused 
service capacity, the cost of serving an additional person would be 
less than the agency's average service cost. However, if an agency is 
operating at capacity, serving compact migrants might require an 
expansion in agency operations, causing the cost of serving compact 
migrants to exceed the average service cost. For a discussion of these 
cost issues, see GAO, Illegal Alien Schoolchildren: Issues in 
Estimating State-by-State Costs, [hyperlink, 
http://www.gao.gov/products/GAO-04-733] (Washington, D.C.: June 21, 
2004). 

[54] U.S. Department of the Interior Office of Inspector General, 
Audit Report: Impact of the Compact of Free Association on the 
Government of Guam, Report No. 93-I-1195 (1993). 

[55] The amended compacts' enabling legislation requires that 
Interior's impact reports include, among other elements (1) the 
governor's comments on the impacts of the compacts, (2) the 
administration's analysis of such impacts, and (3) the administration 
views on any recommendations for corrective action proposed by the 
governors to eliminate compact impact. 

[56] Guam submitted impact reports annually to Interior from 2004 to 
2010, and Hawaii submitted impact reports in 2004, 2007, 2008, and 
2011. The CNMI submitted impact reports as part of its compact impact 
grant proposals annually from 2004 to 2010; however, Interior 
officials said that they did not recognize the analysis in the CNMI's 
grant proposals as compact impact reporting. 

[57] Michael Levin, The Status of Micronesian Migrants in the Early 
21st Century: A Second Study of the Impact of the Compacts of Free 
Association Based on Censuses of Micronesian Migrants to Hawaii, Guam, 
and the Commonwealth of the Northern Mariana Islands (manuscript, 2008 
). The labor force participation rate is defined as those people in 
the labor force divided by the total population aged 16 and older. The 
labor force includes all people classified in the civilian labor force 
(employed or unemployed). 

[58] We did not assess the impact of the presence of compact migrants 
in the labor market on the wages and employment of other labor force 
participants. 

[59] Analysis conducted using the CNMI Department of Finance's data 
assumed that all CNMI residents from the FAS were compact migrants. 

[60] According to data from the U.S. Department of Defense, as of 
August 2011, 300 persons born in the FSM, 65 in Palau, and 16 in the 
Marshall Islands serve in active duty in the U.S. Armed Forces. 
Additional persons born in the FAS serve in the reserve and the 
National Guard. 

[61] Compact migrants paying income tax may qualify for the Earned 
Income Tax Credit and therefore have a negative effect on government 
revenues. 

[62] See appendix I for a discussion of the assumptions made in this 
estimation. 

[63] Our analysis of data on population counts and counts of compact 
migrants shows that in 2009, compact migrant workers could claim, on 
average, 3.9 exemptions and nonmigrant workers 2.8 exemptions. 

[64] Data for compact migrants are from the 1998 surveys of 
Micronesian migrants, and data for the general population are the 
average annual expenditures for households in Honolulu in 1998 from 
the Bureau of Labor Statistics' Consumer Expenditure Survey. 

[65] Estimates for total remittances sent from the U.S. areas to the 
FSM, the Marshall Islands, and Palau range from $1.96 million (based 
on 1998 Micronesian surveys in Guam, the CNMI, and Hawaii. See 
Elizabeth Grieco, The Remittance Behavior of Immigrant Households: 
Micronesians in Hawaii and Guam (2003) for a more detailed analysis of 
this data) to $71 million (an estimate provided by Manuel Orozco, a 
Senior Associate at the Inter-American Dialogue who focuses on 
estimating remittances, see the methodology in Manuel Orozco, 
Estimating Global Remittance Flows: A Methodology, available at 
[hyperlink, www.ifad.org/remittances/maps/methodology.pdf]. For a 
description of the challenges associated with accurately estimating 
remittances, see GAO, International Remittances: Different Estimation 
Methodologies Produce Different Results, [hyperlink, 
http://www.gao.gov/products/GAO-06-210] (Washington, D.C.: Mar. 28, 
2006). 

[66] Through its school leaseback program, Guam contracted with a 
private company to design, construct, and maintain four schools, which 
it currently leases from the company for $7.1 million annually. 

[67] While the appendix contains information on grants available 
through fiscal year 2011, we are using compact impact grant award data 
from 2004 to 2010 to maintain comparability with the time frame of the 
available reported compact impact costs from affected jurisdictions. 
In addition, from 1992 through 2003, Guam received approximately $53 
million, Hawaii $7 million, and the CNMI $6.6 million from funds 
appropriated to Interior for grants to address compact impact. 

[68] State of Hawaii, Department of the Attorney General, Final Report 
of the Compacts of Free Association Taskforce, Pursuant To Senate 
Resolution No. 142, S.D. 1 Regular Session Of 2007, Submitted To The 
Twenty-Fifth State Legislature Regular Session of 2009, available at 
[hyperlink, 
http://archives.pireport.org/archive/2009/November/cofa.pdf]. 

[69] In 2008, community groups in Hawaii worked with state agencies to 
produce a resource guide for migrants. Hawaii Parent Information 
Resource Center, Voyaging Together To A New Life: A Handbook for 
Newcomers to Hawaii, available at [hyperlink, 
http://www.hawaiipirc.org/handbook/index.html]. 

[70] The Center for Micronesian Empowerment is a nonprofit supported 
by private sector donations and three of four states of the FSM who 
use supplemental education grants funds provided by the United States 
through the compact to assist their citizens living in Guam. 

[71] In 1991, the government of Guam requested funding for a compact 
impact public information and education program to assist newly 
arriving FAS citizens. In fiscal year 2010, Interior used a $85,200 
technical assistance grant to fund a video that seeks to prepare 
Marshallese migrants for assimilation to the United States. 

[72] Kokua Kalihi Valley receives federal, state, and private funding. 

[73] [hyperlink, http://www.gao.gov/products/GAO-02-40]. 

[74] Interior made available approximately $557 million to the FSM and 
$250 million to the Marshall Islands from 2004 to 2010. In fiscal 
years 2011 and 2012, Interior made available approximately $80.7 
million and $81.3 million to the FSM, respectively. Interior also made 
available approximately $35.5 million to the Marshall Islands for 2011 
and again in 2012. Sector grant funds made available in a fiscal year 
may be awarded in a later fiscal year. 

[75] [hyperlink, http://www.gao.gov/products/GAO-02-40]. 

[76] The current Marshall Islands population estimate was obtained 
from the Marshall Islands embassy website. Palau population estimates 
are from the United States Census Bureau international database. 

[77] Pub. L. No. 108-188. 

[78] OMB, Questions and Answers When Designing Surveys for Information 
Collections (Washington, D.C.: 2006) and Standards and Guidelines for 
Statistical Surveys (Washington, D.C.: 2006). 

[79] [hyperlink, http://www.gao.gov/products/GAO-02-40]. 

[80] OMB Circular No. A-94. 

[81] [hyperlink, http://www.gao.gov/products/GAO-09-3SP]. 

[82] GAO, Illegal Alien Schoolchildren: Issues in Estimating State-by- 
State Costs, [hyperlink, http://www.gao.gov/products/GAO-04-733] 
(Washington, D.C.: June 21, 2004). 

[83] Michael Levin, The Status of Micronesian Migrants in the Early 
21st Century: A Second Study of the Impact of the Compacts of Free 
Association Based on Censuses of Micronesian Migrants to Hawaii, Guam, 
and the Commonwealth of the Northern Mariana Islands (manuscript, 
2008). 

[84] The analysis assumes that (1) all citizens from the FAS are 
compact migrants, (2) all public and private sector workers earn the 
average wage for their sector, (3) all workers work 40 hours a week 
and 52 weeks a year, (4) workers earn no other income, (5) all workers 
file taxes, (6) all workers take the standard deduction and do not 
take tax credits such as the Earned Income Tax Credit, (7) all workers 
count all nonworking household members as exemptions when filing 
taxes, and (8) workers face tax rates as listed in the 2009 federal 
income tax rate table. 

[85] Only 2 percent of the compact migrant labor force worked in the 
higher paying Guam public sector, while 27 percent of the non-compact 
migrant labor force worked in the public sector in 2009. In 2009, the 
Guam Department of Labor reported that the public sector paid an 
average of $7.31 per hour more than the private sector. The average 
wage for the private sector includes only production (nonsupervisory) 
workers, possibly accounting for part of the difference in wages 
between the private and public sectors. Since compact migrants tend to 
work in production (nonsupervisory) occupations, using this average 
wage for the private sector is appropriate for our purposes. 

[86] GAO, U.S. Insular Areas: Opportunities Exist to Improve 
Interior's Grant Oversight and Reduce the Potential for Mismanagement, 
[hyperlink, http://www.gao.gov/products/GAO-10-347] (Washington, D.C.: 
March 16, 2010). 

[87] From 2000 through 2010, Benton's and Washington County's 
populations increased by 44 and 29 percent, respectively, to a 
combined total of 424,404. The population of the city of Springdale, 
center of the Marshallese population, similarly increased by 52 
percent to 69,797. Benton County is the headquarters of Wal-Mart, and 
Washington County is home to several large poultry companies. 
Northwest Arkansas has a comparatively low unemployment rate and a 
long history of attracting immigrant labor to its poultry industry. 

[88] The tabulated ACS data use place of birth, year of entry, 
relationship to head of household, and age to identify migrants. Prior 
information about the population of migrants in Arkansas since the 
first arrival of Marshallese migrants in the 1970s is limited. 
Marshallese in Springdale estimated that as of the mid-1990s there 
were approximately 15 Marshallese families in the area. However, in 
early 2000, a downsizing in the Marshallese government workforce 
prompted a spike in migration. A pilot study in Arkansas by Interior 
in 2001 interviewed 78 Marshallese households containing 541 migrants 
and estimated the Marshallese population of Arkansas as ranging from 
2,000 to 4,000. For more information, see Michael Levin, The Status of 
Micronesian Migrants in the Early 21st Century, 2008. In 2005, 
Springdale contracted with Census for a special census because of the 
significant general population growth and the influx of Hispanics and 
Marshallese into the city since the decennial census in 2000. The 2005 
special census counted 1,907 persons in the category "Other Pacific 
Islanders"--a number that officials in Arkansas thought to be almost 
exclusively Marshallese. 

[89] This total is for respondents who reported Marshallese race alone 
or in combination with another race. A total of 4,121 persons reported 
Marshallese race alone. 

[90] "Living in Arkansas: What You Need to Know as a Marshallese," 
available at [hyperlink, 
http://www.arminorityhealth.com/pdf/Living_In_Arkansas_Eng_282010.pdf]. 

[91] Prior to the school year beginning in 2009, the Springdale School 
District counted Asian and Pacific Islanders in a single category. The 
estimated Pacific Islander enrollment in the years prior to 2009 
assumes that the percentage of Pacific Islanders within the combined 
category was the same prior to 2009 as it was in the school years 
beginning in 2009 and 2010. 

[92] Marshallese migrants are eligible for some state programs such as 
Mental Health, Alcohol and Drug Abuse, and Child Protective and Foster 
Care services. 

[93] Total for the 50 states include the District of Columbia and 
Puerto Rico. The 2010 census identified 19,841 Native Hawaiian and 
other Pacific Islanders --not in combination with another race--who 
identified themselves specifically as Marshallese. 

[94] Census has published a combined count of "Other Micronesians" 
that combines U.S. residents who reported their race as Mariana 
Islander, Palauan, Carolinian, Kosraean, Micronesian, Pohnpeian, 
Saipanese, I-Kiribati, Chuukese, or Yapese. Census data identify 
44,674 persons who are "Other Micronesian" alone or in combination 
with another race. 

[95] Migration from the Marshall Islands is ongoing, with 
approximately 900 persons leaving each year by air. See Republic of 
the Marshall Islands, Fiscal Year 2009 Economic Review, U.S. 
Department of the Interior and the Pacific Islands Training 
Initiative, Washington, D.C., August 2010. 

[96] See appendix I for information about the sources of these best 
practices and guidance. 

[97] The Guam Bureau of Statistics and Plans (BSP), which is 
responsible for compiling data received from reporting agencies, 
writing annual impact reports, and submitting them to Interior, has 
taken a step to offset this potential for an overcount by subtracting 
the number of compact migrants it identified as present prior to the 
compacts. Although the number of impact school children changes over 
time, Guam subtracts the same number every year. Guam BSP said it 
calculated its baseline based on its interpretation of Interior's 1994 
guidance, by counting the number of migrants from the FAS who were 
present and seeking U.S. citizenship before the compacts were signed. 
Guam identified FSM and Marshallese migrants using the 1980 decennial 
census and identified Palauans using a 1995 special study funded by 
Interior. The Guam government said that its baseline remains the same 
each year because it assumes there will always be an FAS migrant 
population on Guam irrespective of the compacts. 

[98] This analysis is based on Hawaii's compact impact reports 
submitted from 2004 to 2008. The Hawaii Department of Education 
excluded federal funds from its costs reported to Interior in August 
2011. Hawaii developed its educational impact costs by calculating a 
per pupil expenditure multiplied by the number of compact migrant 
students enrolled each school year. Federal funds received through 
several programs are included in these annual expenditures, which 
overstate the costs to the state of Hawaii. These programs include 
Title I, Child with Disabilities program, Child Nutrition Act, Drug- 
Free Schools program, and the Vocational Education program. If the 
federal funds component of per pupil expenditures were subtracted from 
Hawaii's education impact reporting, as well as an adjustment for 
erroneously double counting Marshallese students, it would reduce the 
total cost of services to compact migrants by approximately $61 
million for 2004 through 2008 from $229 to $168 million. 

[99] Guam's technical comments on our draft report asserted that the 
Office of the Governor reports only the local costs for providing 
public services to compact migrants for which federal funding may also 
have been provided. Guam said these reported costs--displacement costs-
-are based on services that the local population could have used 
instead of compact migrants. 

[100] In schools, the number of additional compact migrant students 
will likely have lead to increased capital costs such as additional 
school space. According to school district data for the most recent 
school year - 2010 to 2011-in affected jurisdictions, migrants make up 
21 percent of the student population in Guam, 12 percent in the CNMI 
and 3 percent in Hawaii. As noted above, however, all three affected 
jurisdictions have identified migrant students through the proxy 
definitions of ethnicity or language, which are likely to overstate 
the number of migrants. 

[101] In technical comments on our draft report, Guam asserted that 
compact migrants are generally treated as if they are U.S. citizens 
and that, unless specifically deemed ineligible for programs, compact 
impact reimbursement is justified for all public services rendered. 

[102] U.S. Census Bureau, Final Report: 2008 Estimates of Compact of 
Free Association (COFA) Migrants (Washington, D.C.: 2009). 

[103] Further discussion on Interior's grant management process is in 
GAO, U.S. Insular Areas: Opportunities Exist to Improve Interior's 
Grant Oversight and Reduce the Potential for Mismanagement, 
[hyperlink, http://www.gao.gov/products/GAO-10-347], (Washington, 
D.C.: Mar. 16, 2010). 

[104] GMHA officials stated that this restriction put the Hospital in 
a difficult position because many of the same vendors from whom they 
would purchase supplies were the same ones owed for past bills. 
Interior also denied the Guam Department of Public Works' proposal for 
the purchase of vehicles and equipment, and the Customs and Quarantine 
Agency's purchase of hardware and software, although it approved 
similar grants in previous fiscal years. 

[105] For advocates of primary health care in the Pacific Islands, see 
Neal A. Palafox and Seiji Yamada, "The Health Predicament of the U.S.- 
Associated Pacific Islands: What Role for Primary Care?," Asian 
American and Pacific Islander Journal of Health, 1997(5): 49-55. Also, 
GAO, Medicare: Provision of Key Preventive Diabetes Services Falls 
Short of Recommended Levels, [hyperlink, 
http://www.gao.gov/products/GAO/T-HEHS-97-113] (Washington, D.C.: Apr. 
11, 1997) states that most experts agree that preventive care may help 
control costs for people with diabetes, a disease that is present 
among compact migrants in Hawaii. More generally, GAO, Primary Care 
Professionals: Recent Supply Trends, Projections, and Valuation of 
Services, [hyperlink, http://www.gao.gov/products/GAO-08-472T] 
(Washington, D.C.: Feb. 12, 2008) states that research shows that 
primary care medicine can achieve better outcomes and cost savings. 

[106] For studies describing the need for preventive care among FAS in 
Hawaii see, for example, Jin Young Choi,"Seeking Health Care: 
Marshallese Migrants in Hawaii," Ethnicity & Health, 13(1), January 
2008: 73-92; and Eunice Brekke, Canisius Filibert, and Oramond 
Hammond, "A Study of Individuals and Families in Hawaii From the 
Federated States of Micronesia, the Republic of the Marshall Islands, 
and other Northern Pacific Islands." 

[107] Michael Beaghen and Lynn Weidman, American Community Survey 
Research Memorandum Series, Statistical Issues of Interpretation of 
the American Community Survey's One-, Three-, and Five-Year Period 
Estimates (Washington, D.C.: U.S. Census Bureau, 2008). 

[108] C. Alexander and A. Navarro, "The Quality of Estimates from the 
American Community Survey for Small Population Groups," Proceedings of 
the 2003 Joint Statistical Meetings (2003). 

[109] Kevin Deardorff and Lisa Blumerman, "Evaluating Components of 
International Migration: Estimates of the Foreign-Born Population by 
Migrant Status in 2000". U.S. Bureau of the Census Population Division 
Working Paper Series No. 58 (December 2001). 

[110] OMB, Standards and Guidelines for Statistical Surveys 
(Washington, D.C.: 2006). 

[111] OMB, Standards and Guidelines for Statistical Surveys 
(Washington, D.C.: 2006). 

[End of section] 

GAO’s Mission: 

The Government Accountability Office, the audit, evaluation, and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the 
performance and accountability of the federal government for the 
American people. GAO examines the use of public funds; evaluates 
federal programs and policies; and provides analyses, recommendations, 
and other assistance to help Congress make informed oversight, policy, 
and funding decisions. GAO’s commitment to good government is 
reflected in its core values of accountability, integrity, and 
reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO’s website [hyperlink, http://www.gao.gov]. Each 
weekday afternoon, GAO posts on its website newly released reports, 
testimony, and correspondence. To have GAO e mail you a list of newly 
posted products, go to [hyperlink, http://www.gao.gov] and select “E-
mail Updates.” 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of 
production and distribution and depends on the number of pages in the 
publication and whether the publication is printed in color or black 
and white. Pricing and ordering information is posted on GAO’s 
website, [hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 
MasterCard, Visa, check, or money order. Call for additional 
information. 

Connect with GAO: 

Connect with GAO on facebook, flickr, twitter, and YouTube.
Subscribe to our RSS Feeds or E mail Updates. Listen to our Podcasts.
Visit GAO on the web at www.gao.gov. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 
Website: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]; 
E-mail: fraudnet@gao.gov; 
Automated answering system: (800) 424-5454 or (202) 512-7470. 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov, (202) 512-4400
U.S. Government Accountability Office, 441 G Street NW, Room 7125
Washington, DC 20548. 

Public Affairs: 
Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
U.S. Government Accountability Office, 441 G Street NW, Room 7149 
Washington, DC 20548.